The CMS Moratorium Explained: Operational & Industry Implications


Date/Time: 05/21/2026, 2:00 pm

Provider: SimiTree & Arnall Golden Gregory

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The Centers for Medicare & Medicaid Services has implemented a nationwide 6-month enrollment moratorium on new home health and hospice agencies as part of a broad fraud and program integrity initiative. While positioned as enforcement, the real-world impact is immediate and structural. New entry is paused. Expansion paths are narrowing. Competition is about to intensify. For operators, investors, and providers, this marks a decisive shift in how growth is achieved in post-acute care.

THIS POLICY WILL:

  • Effectively freeze de novo agency formation nationwide
  • Shift growth strategies toward acquisitions and consolidation
  • Increase competition for referrals, staff, and market share
  • Heighten scrutiny and due diligence in transactions (CHOWs and acquisitions)
  • Worsen access constraints in underserved geographies

The result: a faster-moving, more competitive, and more acquisition-driven market.

KEY TAKEAWAYS:

  • Market impact & regulatory shift
  • What happens to growth from here
  • The new competitive playbook
  • M&A and transaction dynamics
  • Operational priorities that now matter most

Understand what this policy shift means before your competitors do.

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