A Narrower Freeze: What Changed In CMS’ Medicare Home Health Moratorium

Last night, amid the Great Outlook Outage of 2026, the Centers for Medicare & Medicaid Services (CMS) announced that it was extending its six-month moratoria on new home health and hospice Medicare enrollments. 

CMS had several shades-of-gray options between extending the freeze as-is and letting it expire. Many advocated for letting it expire, but the agency instead chose to keep the nationwide restrictions while reopening an avenue for existing providers to grow.

This is a meaningful concession on expansion, but it’s not a retreat on enforcement. It creates a sharper divide between providers already inside Medicare and those trying to get in, and according to some advocates, does not go far enough to protect access to care.

The crucial change here is that, unlike the original moratoria implemented in May, the moratoria extensions will allow currently enrolled hospices and home health agencies to add new practice locations within their existing enrollment. CMS’ enrollment guidance specifies that those additions must be in the same state. CMS provided more details in the FAQ it published last night. I’ll review what the difference means in this Update.

In addition to the change for existing home health agencies looking to grow, CMS also shared more information about its approach to fighting fraud. This includes highlighting a recent California-based anti-fraud operation that the agency said resulted in 145 provider revocations tied to more than $703 million in Medicare and Medicaid payments.

Those numbers help explain why and how CMS wants to keep the pressure on. They do not, by themselves, explain why a nationwide enrollment freeze remains the right tool. That distinction matters as a six-month pause becomes a yearlong restriction.

In this week’s exclusive, members-only HHCN+ Update, I’ll unpack the extension, offering insights and takeaways, including:

— The changes in the moratoria

— CMS’ approach to fraud

The differences

CMS is limited in how it approaches moratoria. The agency is statutorily required to implement these in six-month periods, according to Kim Brandt, CMS’ deputy administrator and chief operating officer. But in other ways, the agency can get creative.

The agency has considered creative ways to mitigate the moratoria’s negative side effects, Brandt said at the National Alliance for Care at Home’s (the Alliance) Annual Meeting & Expo in Washington. These include geographic limitations and a “gold card” program, which would provide exceptions for existing providers with strong compliance track records.

There is a precedent for the agency limiting the geographies of a home health enrollment moratorium. The last time CMS implemented such a measure, it started with a narrow geography and then expanded it over time, as it continued to extend the moratorium in six-month increments.

But even at its largest, that moratorium was not nationwide.

I confess that with the focus on home health and hospice hot spots such as California, Arizona, Nevada, Texas and Georgia, and the agency’s history with geographic limits, I expected any extension to be geographically targeted.

Instead, CMS decided to allow existing home health agencies and hospices to add practice locations while keeping the nationwide freeze on new enrollments. CMS drew its new dividing line around enrollment status, not geography. It gives existing providers more room to address unmet demand but leaves prospective new providers unable to make the same case through an initial Medicare enrollment.

I’ll let you read directly from CMS’ FAQ about the extended moratoria:

Although the HHA and hospice moratoria originally prohibited adding a new practice location to an existing Medicare enrollment, as of the effective date of the extension period on Nov. 13, 2026, HHAs and Hospices can add a new practice location to an existing Medicare enrollment. This includes new branches, satellite offices, and expansion locations being added to an existing HHA or Hospice’s CMS Certification Number (CCN). Medicare-enrolled providers can acquire and merge with other enrolled providers during the moratoria and moratoria extension period, provided there are no CIMOs under 42 CFR § 424.550(b) that require a new enrollment. Existing locations transferred to the surviving entity’s enrollment as part of the acquisition or merger are not considered new, as they are already Medicare-recognized and certified.

Under the modified moratoria, home health and hospice agencies can also resubmit applications for new locations that were denied under the original moratoria.

This is not a blanket green light for expansion: A new agency requiring its own initial enrollment remains subject to the freeze, as do nonexempt ownership changes that trigger a new enrollment.

Changes in the extended moratoria are a step in the right direction, according to LeadingAge President and CEO Katie Smith Sloan. However, “extending these moratoria further delays legitimate providers’ ability to establish needed services and leaves communities waiting for care,” she said.

According to Sloan, a continued moratorium risks penalizing legitimate providers and restricting access to care without sufficiently addressing the underlying sources of fraud.

The Alliance voiced support for the narrower restrictions in the modified and extended moratorium. CEO Jennifer Sheets also urged CMS to use the next six months to switch to targeted, data-driven enforcement and sharpen existing tools to remove fraudulent providers from Medicare.

The change in the extension is meaningful. It provides relief.

But it also makes existing providers the principal available route for adding new Medicare-certified locations while the freeze continues.

That may help communities where an enrolled provider is willing and able to expand. It does less for a community where the organization prepared to meet a need requires a new enrollment. Permission for incumbents to grow is not a guarantee that they will grow where access is weakest.

I would also be careful about treating this modification as the first step in an inevitable easing of restrictions. CMS has narrowed the policy once. It has not committed to a gradual reopening.

Some clues in CMS’ announcement suggest the agency isn’t softening too much.

Fraud ethos

CMS began its announcement about the moratoria by saying it is “continuing its aggressive efforts to eliminate persistent Medicare fraud conducted by bad actors in the hospice and home health sectors.”

CMS is not changing tack here.

In the announcement, CMS touted that some of its site visit teams conducted a two-day operation targeting home health agencies and hospices in California. This operation resulted in 145 provider revocations, associated with more than $703 million in Medicare and Medicaid payments, according to the agency.

Revoking existing providers demonstrates the importance of scrutinizing organizations already billing Medicare. It does not, on its own, establish how much additional protection comes from blocking new providers nationwide.

CMS has an answer for why the restrictions remain national: It says a nationwide approach prevents potentially fraudulent operators from circumventing the freeze by moving across state lines.

The agency said that the initial moratoria allowed CMS to conduct targeted investigations and deploy advanced data analytics, but it said the fraudulent circumstances that necessitated the freeze have not yet abated.

“CMS determined that extending the moratoria for an additional six months is necessary so the agency can continue to monitor providers for indicators of fraud, and, when appropriate, take administrative actions such as payment suspension and revocation to combat this conduct,” the agency said in its announcement.

The branch relief softens the enrollment restrictions, but it does not signal a retreat from CMS’ broader fraud strategy. The agency is making room for some growth while keeping its nationwide barrier to new enrollments in place. The question heading into May is what would persuade the agency that its other safeguards can do that work without a nationwide freeze. Its announcement explains why CMS wants more time, but offers less clarity on what would convince it that the freeze has done its job.