CMS Freezes Medicare Enrollments for Six Months: What It Means for Your Healthcare Deal

On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) issued a nationwide moratorium on Home Health Agencies and Hospices enrolled in the Medicare program. This moratorium is substantially similar to CMS’s recent nationwide moratorium that went into effect on February 27, 2026, regarding new Medicare enrollments for Durable Medical Equipment suppliers (“DME Suppliers”). According to CMS, both moratoria were implemented to curtail fraud, waste, and abuse in the Medicare program among these providers and suppliers (collectively, “Providers”).

Key Components of the Moratorium

The moratorium only affects certain Providers submitting new enrollment applications to Medicare. Nonetheless, there are nuances regarding what constitutes a “new enrollment.”

Duration of the Moratorium

The moratorium remains in effect for six months, but CMS will evaluate whether to extend or lift the moratorium before the end of each six-month period.

• Affected Providers
• Home Health Agencies (CHHAs)
• Hospices
• Certain types of Durable Medical Equipment Suppliers
  • 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

New Medicare Enrollments

Generally, the moratorium affects only Providers submitting new Medicare enrollment applications. Existing Providers may continue billing and operating under their current billing numbers. However, Medicare treats certain changes, such as a new tax identification number, a new practice location in another contractor’s territory, or any new or additional DME Supplier location, as new enrollments subject to the moratorium.

Exempt Applications

Customary changes to an existing Provider’s enrollment information will not be impacted by the moratorium. Thus, changes to a Provider’s phone number, address, accreditation body, or billing agency information would be exempt from the moratorium. Applications received by CMS before the effective date are also exempt from the moratorium.

Implications for Healthcare Transactions

The moratorium will impact or postpone the timeline for certain types of Provider transactions. In particular, any change in an affected Provider’s majority ownership within the first 36 months of its initial enrollment in the Medicare program, or during the 36-month period after its most recent change in majority ownership, would require the submission of a new enrollment and thus be subject to the moratorium. For these purposes, majority ownership means acquiring more than a 50% direct ownership interest in the Provider through the cumulative effect of asset sales, stock transfers, consolidations, or mergers. Asset sales generally also require submission of a new enrollment application and therefore would be subject to the moratorium.

Impacts on Medicaid Enrollment

The moratorium leaves it to each state Medicaid agency to decide whether a Medicaid provider moratorium is appropriate. The New York State Department of Health has not issued guidance on how the moratoria may affect its Medicaid enrollment processes. Nonetheless, Providers should be aware that new Medicaid enrollments are typically conditioned on obtaining Medicare enrollments.

Compliance Tips

Existing Providers must ensure that their Medicare enrollment information is up to date and report any changes in information to avoid pauses or gaps in Medicare billing privileges. CHHAs and Hospices must report most changes within 90 days. DME Suppliers are subject to a shorter reporting window and must report changes in enrollment information within 30 days.

New Providers should seek legal advice on whether transactions are subject to the moratorium to avoid barred applications and reduce compliance risks, including civil monetary penalties and Medicare re-enrollment bars.

Additional information on each moratorium can be found via the Federal Register at: https://www.federalregister.gov/d/2026-09717 (Home Health), https://www.federalregister.gov/d/2026-09718 (Hospice), and https://www.federalregister.gov/documents/2026/02/27/2026-03971/medicare-medicaid-and-childrens-health-insurance-programs-announcement-of-nationwide-temporary for DME Suppliers.

Contact Us. If you have any questions about the Moratorium or related healthcare transaction matters, please contact Roopa Chakkappan (716.848.1258), David Stark (716.848.1369), or Peter Godfrey (716.848.1246).