Jacobson - Hospice & Home Health enrollment moratorium
CMS announced a nationwide, six-month enrollment action targeting hospice and home health fraud. New agencies—and some ownership changes—are affected. What Texas providers should know.
What CMS announced
CMS announced an aggressive, nationwide crackdown on fraud in hospice and home health, including a six-month action affecting new hospice and home health agency (HHA) enrollment, with an accompanying FAQ.
What an enrollment moratorium does
A provider enrollment moratorium temporarily pauses CMS's acceptance of new Medicare enrollment applications for the affected provider types and areas. Depending on the terms, it can also reach:
- New practice locations
- Certain changes of ownership (CHOW)
- Reactivations
Existing, properly enrolled providers generally keep billing—but the details matter, and the FAQ controls.
Why it matters for Texas providers
Texas has a large home health and hospice (HCSSA) footprint. If you plan to open, buy, or restructure an HHA or hospice, this can stall or reshape your timeline and deal structure. It also signals heightened program-integrity scrutiny—UPIC/ZPIC activity, audits, and revocations.
What to do now
- If you have a pending or planned enrollment, CHOW, or new location, confirm how the action applies before you proceed
- Tighten enrollment, billing, and documentation compliance now
- Get counsel before responding to any enrollment denial or revocation
How we help
We advise Texas hospice, home health, and other HCSSA practices on enrollment, program integrity, and revocation defense.
Grant McFarland
Super-knowledgeable blogger about healthcare law.