November 13 Is Nine Weeks Out. Here Is the Enrollment-Moratorium Countdown.

The nationwide hospice enrollment moratorium took effect May 13, 2026. The Federal Register notice published May 15, 2026. Under 42 CFR 424.570(b) it runs six months. That clock lands around November 13, 2026 — about nine weeks from today. CMS may extend it in additional six-month increments by a new Federal Register notice, or lift it. This is not a recap of the May announcement. We already published what the freeze blocked on day one. This is the operator countdown: what is still frozen, what was never frozen, and what to have on paper before mid-November if the freeze is extended rather than lifted.

The Clock, Precisely

Do not treat “November” as a vibe. The legal vehicle is a temporary moratorium under 42 CFR 424.570(b). Six months from the May 13, 2026 effective date is approximately November 13, 2026. The Federal Register notice published two days after the effective date, on May 15, 2026. That notice is the document to keep next to the 855A file, not a press-release paraphrase.

CMS can do one of two things as the six-month mark approaches: publish a new Federal Register notice extending the freeze in another six-month increment, or lift it. Historical practice on CMS enrollment moratoria is to extend, not let lapse. Plan operationally for an extension. Hope for a lift. Do not staff, lease, or close a Path A deal on the hope.

What Is Still Blocked

Nothing about the freeze list changed because the calendar moved from May to September. The same four items are still off the table until CMS says otherwise:

• New hospice Medicare enrollment. A CMS-855A filed on or after May 13, 2026 does not get processed into a new hospice CCN while the moratorium is in force.
• New practice locations. Existing providers cannot add a branch / new practice location during the freeze.
• Non-exempt changes in majority ownership (CIMOs) under the 36-month rule. If the hospice initially enrolled in Medicare — or last changed majority ownership — inside the past 36 months, a CIMO that would trigger a new initial enrollment is blocked.
• Service-area expansions into new territory. Growing into geography that is not already on the approved service area is treated as a new enrollment for moratorium purposes.

If you have a pending 855A, a pending CIMO, a signed-but-unclosed APA, or a branch that was supposed to open this fall, inventory it this week. The May post walked the 36-month CIMO mechanics. Use that post for the ownership test. Use this one to put a name on every deal that is still sitting in the freeze.

What Was Never Blocked

The freeze is an enrollment pause, not an operations pause. It does not block:

• Applications filed before May 13, 2026. If the 855A was in the pipeline before the effective date, it continues to be processed.
• Existing operations and billing. Current patients, current claims, current Election Statements, current IDG meetings. You keep operating.
• Routine practice-location moves inside an already-approved service area — moving the office across town is not a new location for moratorium purposes.
• Information updates. Phone numbers, mailing addresses, NPI corrections, contact persons.

And one item operators keep getting wrong in staff meetings: telehealth recertification face-to-face. CMS has clarified, in the home health and hospice moratorium FAQs, that hospices already enrolled in Medicare can continue to use telehealth for the recertification face-to-face encounter. They are not impacted by the nationwide enrollment freeze. The FY2027 final rule separately keeps recert telehealth available through December 31, 2027 for already-enrolled hospices; we covered the coding date in the October 1 operator checklist. Do not shut off telehealth recert solely because of this freeze.

Two Scenarios. Put Both on Paper.

Nine weeks is enough time to write two one-page scenarios. It is not enough time if the first time anyone asks “what if they extend it?” is the week the Federal Register notice drops.

Scenario 1 — CMS lifts the freeze around November 13. Path A new-agency timing comes back on the calendar. That is the start-from-scratch 855A, not a CIMO of an already-enrolled hospice. If that is your plan, the work between now and mid-November is the file you will actually submit: ownership chart, managing employees, practice location, service area, and the compliance posture CMS will run through enhanced oversight on a new hospice. Do not wait for the lift notice to start the binder. A lift is a processing queue, not a head start.

Scenario 2 — CMS extends the freeze another six months. That would push the next decision point into roughly May 2027. Pending 855As stay pending. Pending non-exempt CIMOs stay stuck. Branch and service-area plans stay on the already-approved map. Cash and staffing have to assume you cannot buy your way out of a census or geography problem with a new CCN or a new location. That is the plan to brief the board, not the hopeful one.

You do not need to guess which scenario CMS will pick. You need both written, with a named owner for the Federal Register watch, so the week a notice publishes is a switch-flip rather than a scramble.

This Week’s Punch List

1. Administrator + counsel — inventory every pending 855A and every CIMO deal. Pull the most recent CMS-855A. Confirm the Medicare enrollment-approval date and the date of the most recent change in majority ownership. If either date is inside 36 months, the CIMO is inside the rule. Write the status of every pending application and every letter-of-intent or APA that would require a new initial enrollment. If it is not on one page, it is not inventoried.
2. Owner / board — freeze-versus-lift scenario planning. One page for a mid-November lift. One page for a six-month extension. Names on both. No shared-inbox ownership.
3. Development — Path A new-agency timing. If the plan after a lift is a brand-new hospice 855A, build the file now. If the plan was a CIMO of a hospice still inside the 36-month window, that plan does not become Path A just because you renamed it. Map the actual transaction against the CIMO test before you spend another dollar on a closing date.
4. Finance + HR — cash and staffing if the freeze is extended. You cannot add a location or a new CCN to solve a census or coverage problem while the moratorium holds. Model payroll, lease, and census for six more months of the current map.
5. Compliance — watch the Federal Register for the extension-or-lift notice. The document that matters is a new notice under the same moratorium authority, not a tweet and not a trade-association email. Assign one person to check the May 15 notice docket and CMS moratorium updates weekly through November.
6. Medical director + DPCS — do not shut off telehealth recert. Already-enrolled hospices keep the tool. Confirm the recertification face-to-face policy still allows real-time two-way audio and video. Brief anyone who forwarded the May headline as a reason to pull it.

Further Reading

• CMS Just Froze New Hospice Enrollments Nationwide — the May 13 mechanics, the 36-month CIMO test, and what the freeze signaled on day one
• October 1 Is Five Weeks Out: The FY2027 Final-Rule Checklist — rates, HQRP, the election addendum, and telehealth recert through 2027
• The FY2027 Election Addendum Is Now Law
• Got a Qlarant “Notice of Suspension”? The 15-Business-Day Rebuttal Playbook
• PPEO Is Expanding: What Georgia, Ohio, and Other States Need to Know
• Federal Register — Nationwide Temporary Moratorium (May 15, 2026)
• CMS — Home Health and Hospice Moratorium FAQs (PDF)

The Bottom Line

November 13 is a six-month clock under 42 CFR 424.570(b), not a promised reopen. The freeze still blocks new enrollment, new practice locations, non-exempt CIMOs, and service-area expansions. It never blocked existing operations, pre–May 13 applications, routine moves inside an approved area, information updates, or telehealth recert for already-enrolled hospices. Inventory the 855A and CIMO file. Write the lift scenario and the extension scenario. Watch the Federal Register. Do not pull telehealth recert because of a freeze that does not reach it. Nine weeks is enough if those lines have names on them this week.