CMS Medicare Moratorium on Home Health Agencies: What It Means If You're Thinking About Selling
On May 13, 2026, the Centers for Medicare & Medicaid Services announced a six-month nationwide moratorium on new Medicare enrollment for home health agencies and hospices. If you own a Medicare-certified agency and you have been thinking about your exit, you need to understand what the moratorium changes before making a sale decision.
This article is general information, not legal advice. Medicare enrollment, CHOW, and ownership-transfer rules are fact-specific. Speak with healthcare regulatory counsel before signing transaction terms.
Answer First: What does the CMS moratorium mean for home health agency sellers?
The CMS moratorium does not stop existing Medicare-certified home health agencies from operating, but it can make existing provider numbers more strategically important to buyers because new Medicare enrollment is temporarily restricted. For sellers, the impact depends on certification status, CHOW eligibility, CIMO history, the 36-month rule, compliance history, and transaction structure.
That does not mean every certified agency is suddenly worth more. It means buyers may place more value on clean, transferable Medicare access when starting a new agency is harder.
What the CMS Moratorium Actually Says
CMS has placed a hold on new Medicare enrollment applications for home health agencies and hospices. Existing enrolled agencies can continue delivering services to Medicare beneficiaries.
The moratorium affects entry. A new operator that wants to start a Medicare-certified home health agency or hospice from scratch may be blocked from obtaining a new Medicare number during the moratorium period.
CMS framed the action as a fraud, waste, and abuse prevention measure. The agency cited intensified investigations, provider removals, hospice site visits, heightened oversight in fraud-risk states, enhanced home health agency screening, and expanded claims review activity.
CMS may extend the moratorium in additional six-month increments.
The Acquisition Issue: CIMOs, CHOW, and the 36-Month Rule
The key issue for sellers is whether a transaction can proceed through a clean CHOW or whether it triggers initial enrollment.
CMS says the moratorium also applies to initial applications that include non-exempt changes in majority ownership, known as CIMOs, under 42 CFR 424.550(b).
Under that rule, if a home health agency or hospice has a change in majority ownership within 36 months of initial Medicare enrollment or within 36 months of its most recent CIMO, the Medicare provider agreement and billing privileges generally do not automatically convey to the new owner. The buyer may need to enroll as a new provider and obtain state survey or accreditation. During the moratorium, that path may be blocked.
There are exceptions. The rule may not apply if the provider has submitted two consecutive years of full cost reports since initial enrollment or the last CIMO. Other exceptions may include internal corporate restructuring, same-owner entity structure changes, and individual owner death.
This is why CHOW planning matters. A sale that can proceed through assignment of an existing provider agreement is very different from a sale that triggers initial enrollment.
What This Means for Your Agency’s Value
Medicare certification has always carried value. It takes time, cost, and compliance discipline to obtain. When CMS restricts new enrollment, existing certified agencies can become one of the few viable paths for buyers that need Medicare access.
Strategic acquirers, private equity-backed platforms, and regional operators may prefer to acquire an existing certified agency instead of waiting for new enrollment availability.
That does not guarantee a higher sale price. Agency value still depends on revenue, payer mix, census, geography, leadership stability, compliance history, margins, owner dependence, and transferability.
The moratorium is a market factor. It is not a valuation promise.
Can You Still Sell During the Moratorium?
Yes, many agencies can still sell during the moratorium. Whether a sale can proceed depends on the agency’s enrollment history, ownership history, transaction structure, and applicable state and federal rules.
If the agency has been operating long enough to avoid the 36-month CIMO issue, or if the transaction is structured in a way that does not trigger initial enrollment, the sale may still move through the standard CHOW process.
Asset sales, stock sales, membership interest transfers, mergers, and consolidations can create different Medicare enrollment consequences. Do not generalize. Have healthcare regulatory counsel review the structure before terms are finalized.
What Agency Owners Should Do Right Now
Start with three steps.
Get a confidential valuation. You cannot make a timing decision without knowing what your agency may be worth in the current market.
Confirm your CIMO history. Know your initial Medicare enrollment date and whether any majority ownership change occurred in the last 36 months.
Talk to specialists before going to market. Home health and hospice transactions involve CHOW, Medicare enrollment, state licensure, accreditation, and sometimes CON issues.
At Home Care Business Broker, we work with owners of home care, home health, hospice, and senior care businesses that need a confidential, industry-specific exit process.
Frequently Asked Questions
Does the CMS moratorium affect my existing home health agency?
No. If your agency is currently enrolled with Medicare, it can continue delivering services to beneficiaries. The moratorium blocks new enrollment applications; it does not stop existing certified providers from operating.
Can I still sell my home health agency during the moratorium?
In many cases, yes. Whether a sale can proceed depends on the agency’s enrollment history and transaction structure. Deals that do not trigger initial enrollment requirements may still move through CHOW.
Does the Medicare moratorium increase my agency’s value?
It may improve buyer demand for clean, existing certified agencies because new enrollment is restricted. But value still depends on financials, payer mix, census, compliance history, leadership, geography, and transferability.
What happens to my Medicare number when I sell?
The Medicare provider agreement and billing privileges may convey through CHOW if the transaction is structured correctly and does not trigger initial enrollment. Certain changes in majority ownership inside the 36-month window may prevent transfer.
What is CHOW in a home health agency sale?
CHOW stands for Change of Ownership. It is the process used to report and process ownership transfer for a Medicare-certified provider.
What is the 36-month rule?
The 36-month rule says that if a Medicare-certified home health agency or hospice has a change in majority ownership within 36 months of initial enrollment or its most recent CIMO, the provider agreement and billing privileges generally do not convey to the new owner. Exceptions exist, so counsel should review the facts.
