The CMS home health enrollment moratorium expires November 12. CMS can extend it with no advance notice.

The six-month nationwide enrollment moratorium CMS imposed on May 13, 2026 reaches its expiration date on November 12, 2026. Under 42 CFR § 424.570(a)(2), CMS may extend it for successive six-month increments — or let it expire — and is not required to provide advance notice before either action. For agencies with pending transactions, planned branch expansions, or M&A under discussion, the 38-day countdown is not a safe harbor. It is a deadline with unknown downstream conditions.

In September, the two largest home health and hospice associations submitted formal letters urging CMS not to extend. The National Alliance for Care at Home sent its letter on September 4; LeadingAge — which had originally supported the moratorium — sent its own on September 9. Both argued that the fraud risk justifying a nationwide freeze is geographically concentrated, not a uniform national problem, and that a blanket extension penalizes compliant agencies in markets without elevated fraud indicators.

Jennifer Sheets, CEO of the Alliance, wrote that "national data does not demonstrate that fraud, waste or abuse in home health or hospice is so pervasive and geographically uniform as to warrant an extension of the enrollment moratoria across all 50 states and territories." The Alliance cited that 38% of Medicare beneficiaries referred for home health after hospital discharge in Q3 2025 did not receive those services — noting that while the moratorium did not cause that access gap, a continued extension prevents providers best positioned to close it from entering the market.

What is still blocked under the moratorium

Until the moratorium lifts, three categories of Medicare enrollment activity remain frozen:

• Initial enrollment: New HHAs cannot apply for a Medicare CMS Certification Number. Applications submitted after May 13 are denied by the MAC without processing.
• Changes in majority ownership within 36 months of initial enrollment (CIMOs): Under 42 CFR § 424.550(b), an HHA that changes majority ownership within 36 months of its initial enrollment (or its most recent CIMO) must re-enroll as a new provider. That re-enrollment is blocked. M&A transactions that trigger a CIMO for a recently enrolled agency are structurally stalled until the moratorium lifts.
• New branch and practice locations: Adding a new service area, satellite office, or branch to an existing CMS Certification Number requires an initial enrollment application — also frozen.

What is not blocked: routine administrative updates, standard ownership transfers that do not trigger the 36-month CIMO rule, and applications received by a MAC before May 13, 2026 (grandfathered under 42 CFR § 424.570(a)(1)(iv)).

Why the no-notice provision matters

A typical federal rulemaking carries a published notice and comment period. The moratorium mechanism under 42 CFR § 424.570 does not. CMS can extend the freeze before November 12 with no announcement, or let it expire quietly. Agencies treating November 12 as a firm planning horizon are making a calculation that the regulatory process does not support.

CMS could also extend the moratorium selectively — in specific states or metro areas with the highest fraud indicators — rather than nationwide. That proportionate approach is exactly what both the Alliance and LeadingAge proposed in their September letters. A geographically targeted extension would lift the freeze on compliant agencies in low-risk markets while maintaining it in the zip codes where enrollment spikes and fraud patterns are concentrated. Whether CMS takes that path or a broader one is not yet known.

What your agency should do before November 12

1. If you have a pending M&A transaction that requires a CIMO re-enrollment, get legal counsel now on whether the transaction can be structured to avoid triggering the 36-month rule. Deal timelines set to close "after the moratorium lifts" carry execution risk if the freeze extends another six months. Transaction structure matters before signing a letter of intent, not after.
2. If you are planning a branch expansion, complete the pre-work now so you can file on day one if the moratorium lifts November 12. MAC processing for an initial enrollment application takes 90 to 150 days from receipt. An application filed promptly on November 13 would yield Medicare billing capability in Q1–Q2 2027. An application filed in December yields it in Q2–Q3 2027.
3. Model both scenarios: moratorium lifts November 12, moratorium extends to May 13, 2027. Your 2027 budget assumptions around new service territories, acquisition timelines, and organic expansion need to hold under both outcomes. Agencies that have only modeled the "lifts in November" scenario are planning against one of two equally plausible futures.
4. Monitor CMS press releases from mid-October onward. The initial moratorium announcement in May came with roughly one week of public notice. A comparable timeline for the extension or expiration decision is plausible. There is no formal comment process — the announcement, if one comes, will be the decision.

What we built for this

Carelytic's compliance hub keeps each agency location's Medicare enrollment status, initial certification date, and most recent CIMO date visible in one view. That means the 36-month CIMO re-enrollment window — the threshold that determines whether a majority-ownership change requires new enrollment and is therefore currently blocked — is calculated automatically from the record, not reconstructed from MAC correspondence when a transaction surfaces. For agencies managing multi-location operations or exploring M&A, the enrollment calendar is part of the compliance dashboard rather than a separate spreadsheet. When the moratorium decision arrives — with or without advance notice — the data to act is already in the platform.