CMS Moratorium: What's Next for Providers and How to Prepare

The Centers for Medicare & Medicaid Services (CMS) implemented nationwide enrollment moratoria on new hospice and home health agencies that are scheduled to expire on November 13, 2026. Unless CMS extends them, the restrictions on new Medicare enrollments and certain ownership changes could soon be lifted.

For six months, expansion plans for many home health and hospice providers have been on hold. New agency launches have been delayed, certain acquisitions have stalled, and some smaller operators looking to sell or retire have faced unexpected challenges. Now the question is what happens next and which providers will be best positioned to act.

Why CMS hit pause

On May 13, 2026, CMS imposed six-month moratoria on new Medicare enrollments for home health agencies and hospices nationwide. The restrictions also apply to certain changes in majority ownership that require a new Medicare enrollment. Agencies already enrolled in Medicare can continue operating as usual (CMS).

The move came amid a sharper federal focus on fraud, waste and abuse in both sectors. During the pause, CMS said it would expand targeted investigations, lean harder on data analytics, and move faster to remove suspect providers. CMS committed to giving at least 60 days’ notice before the moratoria end, but as of mid-October it had not said whether it would extend them (Home Health Care News).

The impact has been real for legitimate operators too:

New agency growth stalled. Providers planning to launch new agencies or expand into underserved markets through new Medicare enrollments faced restrictions.
Deals slowed. Transactions requiring new Medicare enrollments faced delays, while uncertainty complicated M&A planning.
Application processing challenges emerged. Although CMS guidance allows applications received before May 13 to continue through processing, some providers have reported denials involving earlier filings.

What to expect when the moratoria lift

If CMS allows the moratoria to expire, providers could see an increase in enrollment applications as delayed expansion plans and transactions move forward.

Potential application processing delays. An increase in filings could create backlogs as Medicare Administrative Contractors work through new applications.
New competitors in your market. Agencies that have been waiting to enter new markets may resume expansion plans, potentially competing for referrals from the same hospitals, physicians, and skilled nursing facilities (SNFs).
M&A activity could accelerate. Buyers and sellers who paused transactions may re-engage, making reliable market data, referral relationships, and quality performance important considerations.
Continued regulatory scrutiny. The federal focus on fraud, waste, and abuse is unlikely to disappear when the moratoria end. Providers should anticipate continued oversight and potential changes to enrollment requirements.

If CMS extends the restrictions instead, new agency growth will remain constrained, increasing the importance of identifying opportunities within existing markets.

Either way, providers with a clear understanding of their markets will be better positioned to make informed growth decisions.

Five ways to get ready now

Pressure-test your expansion targets. Revisit the markets you put on hold in May. Evaluate current patient volume, competitor saturation, and referral patterns to identify which opportunities offer the greatest potential before moving forward with new enrollment applications.
Lock in your referral relationships. New entrants will court your top referral sources. Know which hospitals, physician groups and SNFs drive your census, and make sure your team is in front of them now.
Size up the competition. Identify who is likely to enter or grow in your service area, and how their quality and utilization compare with yours.
Get deal-ready. If you’re planning to buy, sell, or affiliate, organize your market share, referral, and quality data to help support due diligence and inform transaction decisions once applicable enrollment restrictions are lifted.
Monitor CMS announcements. Watch for official guidance on whether the moratoria will expire or be extended, along with any additional federal or state-level requirements. Maintain a plan for either outcome.

Prepare for What’s Next with Trella Health

When the market reopens, speed and precision win. Trella Health gives home health and hospice leaders the market intelligence to act on day one, by connecting fragmented data and embedding intelligence in your team’s workflows.

Trella Insights provides visibility into market share, referral patterns, patient volume, payer mix, quality metrics, and competitor performance to help you evaluate expansion opportunities and identify shifts in your market.
Trella CRM helps sales teams manage referral relationships, track activity, identify opportunities, and prioritize outreach with AI-enabled workflows.
Trella Community helps post-acute providers connect with hospital discharge teams, receive referrals, and coordinate care transitions.

Whether the moratoria lift on November 13 or CMS extends them, the agencies with the clearest view of their market will grow fastest.

Request a demo to see how Trella Health can help you plan your next move.

A woman with long brown hair, wearing a sleeveless light blue top with gold buttons, sits indoors and smiles at the camera.

Toni Adams

Digital Marketing Manager

Toni Adams is a Digital Marketing Manager at Trella Health with 10+ years of experience blending strategy, creativity, and data across global markets. With a background spanning content, design, and campaign strategy, she’s passionate about creating meaningful, personalized experiences that drive engagement and results. She holds an MBA in Marketing from Johns Hopkins University and a BFA from the University of North Florida.