The federal government has dramatically escalated its anti-fraud enforcement posture, imposing back-to-back nationwide enrollment freezes across three major provider categories in a span of less than three months. The latest action, a pair of six-month moratoria on new hospice and home health agency (HHA) enrollments, follows the first-ever national moratorium on durable medical equipment suppliers and signals a sea change in how the Centers for Medicare & Medicaid Services (CMS) is wielding one of its most powerful program-integrity tools.
The New Moratoria: Hospice and Home Health
On May 13, 2026, CMS announced a six-month nationwide moratorium on new Medicare enrollments for both hospices and home health agencies, citing concerns about rapid enrollment growth, improper ownership transfers, and fraudulent billing activity. The action was coordinated with Vice President JD Vance’s Anti-Fraud Task Force and is part of what CMS is calling its “CRUSH” fraud initiative.
The two moratoria, published as companion Federal Register notices, prohibit CMS from processing new Medicare enrollment applications for HHAs and hospices anywhere in the United States, including all states, territories, and the District of Columbia. The freeze also extends to new branch offices and hospice practice locations, and in many cases applies to certain changes in majority ownership (CIMO) that trigger a new enrollment requirement under the 36-month rule.
Importantly, existing enrolled providers are not affected: current hospices and HHAs may continue delivering services and billing Medicare uninterrupted, assuming they remain in compliance. Applications submitted to a Medicare Administrative Contractor before May 13, 2026, are grandfathered.
CMS Administrator Dr. Mehmet Oz has indicated the agency will use the moratorium period to “aggressively identify, investigate, and remove” existing providers suspected of exploiting the programs — meaning the freeze on new entrants comes alongside heightened scrutiny for those already enrolled. CMS has cited recent enforcement actions as a precursor to the freeze, including the suspension of payments to more than 700 hospices and HHAs in Los Angeles alone, totaling approximately $70 million.
The moratoria may be extended in successive six-month increments if CMS determines continued program integrity risks warrant doing so. Any extension would be announced through the Federal Register. The initial period runs through approximately November 13, 2026.
What the moratoria block:
- Initial Medicare enrollment applications for new hospices or HHAs
- Applications for new HHA branch offices and hospice practice locations requiring enrollment approval
- Certain changes in majority ownership that trigger a new enrollment requirement under the 36-month rule
What they do not block:
- Medicaid enrollments (state agencies determine their own response)
- Existing enrolled providers continuing to bill Medicare
- Applications submitted prior to May 13, 2026
The Precedent: The First-Ever National DMEPOS Moratorium
The hospice and home health freezes build directly on a landmark action taken just weeks earlier. On February 27, 2026, CMS imposed a six-month nationwide moratorium on new Medicare enrollment for seven categories of DMEPOS (Durable Medical Equipment, Prosthetics, Orthotics, and Supplies) medical supply companies — a step that marked the first-ever national moratorium in CMS’s use of this authority.
The DMEPOS moratorium was announced on February 25, 2026, and took effect upon Federal Register publication on February 27. It applies to initial enrollment applications and to certain changes in majority ownership for medical supply companies, citing longstanding and escalating concerns about fraudulent billing schemes in the DMEPOS sector. With over 79,000 DMEPOS suppliers of all types currently enrolled — including more than 6,000 medical supply companies — CMS determined the existing network is sufficient to meet beneficiary needs without new entrants.
The seven supplier types subject to the DMEPOS moratorium are:
- Medical Supply Company
- Medical Supply Company with Orthotics Personnel
- Medical Supply Company with Pedorthic Personnel
- Medical Supply Company with Prosthetics Personnel
- Medical Supply Company with Prosthetic and Orthotic Personnel
- Medical Supply Company with Registered Pharmacist
- Medical Supply Company with Respiratory Therapist
Like the hospice and HHA moratoria, the DMEPOS freeze lasts six months but can be extended in six-month increments. It remains in effect as of this writing.
A Brief History: From Geographic Targeted Actions to Nationwide Freezes
CMS has held statutory authority to impose temporary enrollment moratoria since the Affordable Care Act added Section 1866(j)(7) to the Social Security Act in 2010. For years, the agency used this authority cautiously and geographically — targeting specific counties or metro areas with unusually high fraud indicators.
The first use of the authority came in 2013, when CMS imposed enrollment moratoria on new home health agencies in Miami-Dade County (Florida) and Cook County (Illinois), as well as on Part B ambulance suppliers in Harris County (Texas). The following year, CMS expanded the HHA moratoria to additional counties in Florida, Texas, and Michigan and again expanded the HHA moratoria in these states statewide in 2016.
That original 2013 moratorium was extended repeatedly in six-month increments — a pattern that industry experts note is entirely possible with the current freezes. After being extended and revised multiple times over six years, the geographic moratoria on HHAs and ambulance suppliers finally expired in January 2019.
The shift to national moratoria represents a qualitative change in strategy. Rather than targeting specific hot spots, CMS is now treating entire provider categories as high-risk. The February DMEPOS moratorium was the first time CMS had ever deployed this authority on a nationwide basis. The May hospice and HHA moratoria follow the same template, explicitly citing the DMEPOS action as the model.
As CMS noted in its Federal Register notice for the HHA moratorium: the nationwide approach is designed to prevent providers from evading detection by simply shifting operations across state lines.
Implications and Industry Reaction
For providers, the practical consequences are significant. Any entity that planned to enter the home health or hospice market must now wait until at least November 2026 (if the moratoria are not extended). Deals structured as asset acquisitions or changes in majority ownership need careful scrutiny to determine whether they trigger the enrollment requirement — and therefore the moratorium.
The American Hospital Association raised access-to-care concerns in response to the hospice and HHA freezes, noting that hospitals in rural and underserved areas often struggle to find discharge locations for patients, and that home health and hospice providers are critical to ensuring safe transitions. The AHA called on CMS to consider a more targeted, data-driven approach that distinguishes bad actors from high-quality providers.
The National Alliance for Care at Home similarly argued that enrollment moratoria do not distinguish between fraudulent operators and compliant providers, and that broad freezes risk reducing competition, slowing innovation, and limiting patient access — particularly in rural markets.
CMS, for its part, has stated it does not anticipate harm to beneficiary access. But industry observers note that based on the 2013 precedent — six years of repeated six-month extensions — providers and deal-makers should plan for these moratoria to remain in place well beyond their initial terms.
What Comes Next
With three major provider categories now under nationwide enrollment freezes, the central question is whether CMS will extend these moratoria past their initial six-month windows — and whether additional categories are next.
Providers currently enrolled in any of these sectors should use this period to strengthen compliance programs, shore up documentation practices, and prepare for the increased audits and claims denials that CMS has signaled are coming. Those planning transactions involving home health, hospice, or DMEPOS assets should work carefully with counsel to determine whether the moratorium’s scope would be triggered by a given ownership structure.
And given CMS’s stated intent to expand its use of data analytics and targeted investigations during the freeze, the moratorium may well prove to be the beginning of a more sustained enforcement wave — not merely a temporary pause.
Federal Register notices:
- DMEPOS: Announcement of Nationwide Temporary Moratoria on Enrollment of DMEPOS Supplier Medical Supply Companies (Feb. 27, 2026)
- Home Health Agencies: Federal Register Doc. No. 2026-09717 (May 13, 2026)
- Hospices: Federal Register Doc. No. 2026-09718 (May 13, 2026)