CMS Imposes Nationwide Moratorium on New Hospice and Home Health Medicare Enrollments
What Ohio Providers Need to Know
The Centers for Medicare & Medicaid Services (CMS) has announced sweeping new nationwide enforcement actions targeting fraud, waste, and abuse within the hospice and home health sectors, including a six-month nationwide moratorium on new Medicare enrollments for hospices and home health agencies (HHAs). The moratorium takes effect today, May 13, 2026.
CMS stated the action is part of a broader federal anti-fraud initiative and reflects growing concerns regarding systemic fraud, questionable ownership activity, inappropriate billing practices, and rapid provider growth patterns in portions of the hospice and home health industries.
Importantly, existing Medicare-certified providers may continue operating and serving beneficiaries without interruption.
What the Moratorium Means
The moratorium apply to:
- New Medicare hospice enrollments
- New Medicare home health agency enrollments
- Certain changes in majority ownership (CHOW/CIMO transactions) that require initial enrollment
- Certain new branch or practice location activity requiring enrollment approval
Applications received by Medicare contractors prior to the effective date are generally not subject to the moratorium. Routine provider updates such as phone numbers or address changes also generally remain permissible.
CMS may extend the moratorium in additional six-month increments if it determines continued action is necessary.
Heightened Scrutiny on Ownership and Enrollment Activity
CMS specifically emphasized concerns regarding ownership transfers, “flipping” of providers, concealed ownership arrangements, and rapid enrollment growth patterns.
For both hospices and HHAs, providers should exercise caution regarding:
Changes in majority ownership
- Pending acquisitions or sales
- New branch or location expansion
- Enrollment restructures
- New entity formation
Under existing Medicare regulations, certain ownership changes occurring within 36 months of enrollment may require the provider to enroll as a new entity. During the moratorium period, those transactions could face denial or significant disruption.
Providers considering ownership transactions are strongly encouraged to seek enrollment and legal guidance before proceeding.
Home Health: Key CMS Focus Areas
CMS cited longstanding concerns surrounding home health fraud, including:
- Billing for medically unnecessary services
- Kickback arrangements
- False documentation
- Services not actually rendered
- Shared or suspicious practice locations
- Market oversaturation patterns
CMS specifically referenced recent Ohio findings involving multiple HHAs operating from the same practice location address.
Recommended Actions for Home Health Providers
LeadingAge Ohio encourages HHAs to:
- Review PECOS enrollment records for accuracy
- Confirm ownership and managing employee disclosures are current
- Review branch and practice location structures
- Audit referral relationships and financial arrangements
- Ensure documentation supports:
- Homebound status
- Skilled need
- Physician orders
- Medical necessity
- Plan of care compliance
- Review claims denial and ADR trends
- Prepare for heightened survey and claims review activity
Hospice: Key CMS Focus Areas
CMS outlined concerns involving:
- Certification of ineligible beneficiaries
- Patients enrolled without full understanding or consent
- Minimal or absent services
- Improper physician certifications
- Kickback arrangements
- “Churn and burn” hospice ownership schemes
- Concealed ownership structures
CMS also noted hospices were elevated to the “high-risk” screening category beginning in 2024, resulting in stricter enrollment scrutiny, fingerprinting requirements for certain owners, and expanded site visit activity.
Recommended Actions for Hospice Providers
LeadingAge Ohio encourages hospices to:
- Review PECOS enrollment information for accuracy
- Confirm administrator and medical director reporting requirements are met
- Review ownership disclosures and managing employee reporting
- Audit eligibility and certification documentation
- Review physician narrative support and LCD alignment
- Evaluate live discharge patterns and utilization trends
- Review referral source relationships and medical director agreements
- Ensure certifying physicians meet Medicare enrollment or opt-out requirements
- Prepare for increased site visits, data monitoring, and claims scrutiny
Telehealth Considerations
CMS clarified that the moratorium do not eliminate existing telehealth flexibilities.
For hospice providers, telehealth face-to-face recertification flexibility currently remains extended through December 31, 2027, subject to CMS requirements and restrictions. Providers should continue monitoring CMS guidance regarding modifier, coding, and compliance requirements tied to telehealth encounters.
Ohio Providers Should Expect Increased Oversight
CMS specifically identified Ohio among states receiving heightened review activity and expanded oversight attention.
Providers should anticipate increased scrutiny related to:
- Enrollment records
- Ownership changes
- Claims patterns
- Site visits
- Survey activity
- Documentation compliance
- Referral relationships
- Medical necessity support
LeadingAge Ohio Will Continue Monitoring Developments
LeadingAge Ohio will continue reviewing CMS guidance, Federal Register notices, and operational implications related to these actions and will provide additional updates, education, and compliance resources as information becomes available.
Federal Register Notices
This is an emerging story, and members should stay tuned to the Home Health and Hospice Newsletter. LeadingAge Ohio has been sounding the alarm on potential fraud in Ohio, specifically with hospices. More information, including upcoming legislation, will be sent to members soon. For more information contact Cara Wickham, Director of Home Health and Hospice, at cwickham@leadingageohio.org.
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