On May 13, 2026, the Centers for Medicare & Medicaid Services announced two separate six-month nationwide moratoria — one for new hospices, one for new home health agencies — that block new Medicare enrollment in every state, every territory, and the District of Columbia. The Federal Register notices published two days later. It is the most sweeping single-day action the hospice industry has ever absorbed.

If you already operate a hospice, you can keep operating. You can keep billing. You can keep admitting patients. But if you were planning to open a new agency, add a branch, expand into a new service area, or sell your hospice in the next six months, the rules just changed under you. Here is the operator-level breakdown of what is actually blocked, what is exempt, and what the moratorium signals about the next twelve months of enforcement.

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Bring your questions on CDPH’s emergency hospice licensing regulations (Title 22) — nurse ratios, management qualifications, CHOW, and the licensing moratorium. Zoom link sent by email when you register. The first 3 seats each Wednesday session are free.

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What Was Announced and Who Announced It

The announcement came jointly from Vice President J.D. Vance and CMS Administrator Dr. Mehmet Oz, the same two officials running the federal anti-fraud task force created by executive order in March 2026. The legal vehicle is two parallel notices in the Federal Register (one hospice, one home health) under CMS’s longstanding statutory authority to pause Medicare enrollment in geographies showing a significant potential for fraud, waste, or abuse.

What is different about this one is the scope. Past CMS moratoria have been geographic — a metro area, a state, sometimes a handful of counties. This one is the whole country.

What the Moratorium Actually Blocks

  • New hospice or home health Medicare enrollment applications submitted on or after May 13, 2026
  • New hospice practice locations (branches) opened by existing providers
  • Most changes of majority ownership that would trigger a new initial enrollment — specifically, any non-exempt CIMO occurring within 36 months of the agency’s original Medicare enrollment date or its most recent change in majority ownership (the “36-month rule”)
  • Expansion of an existing agency’s approved service area into new territory

What the Moratorium Does Not Block

  • Applications submitted before May 13, 2026. If your CMS-855A was in the pipeline before that date, it continues to be processed.
  • Existing operations. Current patients, current billing, current claims, current Election Statements, current IDG meetings — all unaffected.
  • Routine practice location changes within an already-approved service area (e.g., moving your office across town).
  • Information updates. Phone numbers, mailing addresses, NPI corrections, contact persons.
  • Indirect ownership changes that do not require an initial enrollment — e.g., changes inside a holding company structure that do not flip majority control of the licensed entity.

The 36-Month Rule Is the Real M&A Killer

The piece getting the least attention in operator-facing coverage so far is also the one most likely to blow up a transaction. The change-of-majority-ownership prohibition is not just about new ownership groups; it applies to any hospice that initially enrolled in Medicare — or last changed majority ownership — within the past 36 months.

What that means in practice:

  • A hospice that enrolled in 2024 cannot be sold via a majority-ownership change today without being blocked for the duration of the moratorium.
  • A hospice that was already sold in 2023 cannot be sold again now if the prior CIMO is still inside the 36-month window.
  • Letter-of-intent deals, signed-but-unclosed APAs, and any transaction where the buyer was depending on a new Medicare enrollment for the acquired entity are now stuck until the moratorium lifts — or longer.

Equity and structural changes that do not trigger an initial enrollment are still on the table. That includes minority investments, certain holding-company reorganizations, and management agreements where the licensed entity does not change hands. If you are in the middle of a deal, get your transaction counsel to map every party against the CIMO test before you do anything else.

Why CMS Did This Now

The growth data CMS published with the moratorium is the cleanest argument for why the agency moved nationwide instead of state-by-state:

  • Nevada hospices grew 151% between 2019 and 2023
  • California hospices grew 126% in the same period
  • Los Angeles County home health agencies grew 40% between 2019 and 2024
  • LA County now contains roughly one-third of the nation’s hospice providers despite holding only 2.5% of the elderly population

That last figure is the one that did it. CMS’s position is that a 13:1 over-representation of hospice providers relative to elderly population in a single county cannot be explained by demand. They are no longer treating the imbalance as a state-level California problem; they are treating it as a national enrollment problem, because the patterns that produced it (low startup cost, limited supervision, the “hospice gold rush”) are present everywhere.

How This Connects to the 447 Suspensions

The moratorium is the supply-side companion to the Qlarant enforcement wave covered in our April 2026 suspension breakdown. Those 447 letters — now closer to 800 with the May expansion — cut off the cash flow of providers CMS suspects of fraud. The moratorium prevents the next 447 from enrolling in the first place. The two policies run in parallel:

  • Suspensions clean up the existing population using the 15-business-day rebuttal process and the live discharge rate flag (covered here)
  • The moratorium freezes the inflow of new providers while CMS expands its data-mining and re-evaluates enrollment criteria

Operators who have been paying attention since the PPEO expansion to Georgia and Ohio already know the direction of travel. The May 13 action is the same trajectory, applied nationally.

Industry Reaction

The trade associations have split on the moratorium. The National Alliance for Care at Home (Jennifer Sheets, CEO) urged CMS to use “data-driven, risk-based program integrity measures…without potentially limiting patient access to care or punishing high quality providers operating in good faith” — effectively asking that the freeze be tightened, not lifted. The National Partnership for Healthcare and Hospice Innovation (Tom Koutsoumpas) was more supportive, framing fraudulent operators as undermining public trust.

The split matters because it tells you which arguments are likely to get traction in the next six months. “Lift the moratorium” will not. “Make the moratorium more surgical” might. Operator-facing advocacy is going to live in the second bucket.

What Operators Should Do This Week

  1. Inventory your enrollment posture. Pull your most recent CMS-855A. Confirm the date your Medicare enrollment was approved and the date of your most recent change in majority ownership, if any. If either date is inside the past 36 months, you are inside the rule.
  2. If you have a pending deal, freeze the closing schedule. Get transaction counsel to map every owner, member, partner, and parent entity against the CIMO test before you sign anything that triggers a new enrollment.
  3. If you have a pending branch or service area expansion, expect it to be denied. CMS is treating expansion into new geographies as a new enrollment for moratorium purposes. Re-plan around your already-approved area.
  4. Tighten your compliance posture. The moratorium is a six-month window in which CMS has explicitly said it will increase investigations and use advanced analytics to detect suspicious ownership changes, billing patterns, and potential fraud. Your live discharge rate, your cap utilization, your length-of-stay distribution, and your medical director affiliations are all visible to that analysis right now.
  5. Assume the moratorium will be extended. The 6-month timer can be extended in additional 6-month increments at CMS’s discretion. Historical practice on CMS moratoria is to extend, not let lapse. Plan operationally for 12 months minimum.

Compliance & Enrollment Consulting: $300/hour

If you are mid-transaction, mid-expansion, or just trying to make sense of how the moratorium hits your specific structure, we can help you map the CIMO test against your ownership chart and identify what is and is not blocked. Same consultants who work the Qlarant rebuttals.

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Further Reading

The Bottom Line

The moratorium does not touch your day-to-day clinical and billing operations. It does freeze the entire M&A market for hospices and home health agencies inside the 36-month CIMO window, halts new branches and new service areas, and signals that CMS is going to spend the next six months pointing its analytics engine at the providers it already has. The April Qlarant suspensions were the demand-side cleanup. May 13 is the supply-side cleanup. The next twelve months belong to whichever operators run cleanest under that analytics regime.