The moratorium applies only to new enrollments and certain ownership-change transactions treated as new enrollments under Medicare rules. Existing certified home health agencies and hospices retain their current enrollments and billing authority. The specific mechanics of how CMS will treat transactions involving changes of ownership, restructurings, and other corporate events remain to be clarified in forthcoming guidance.
Attorneys advising home health and hospice providers, investors, and acquirers should immediately assess pending enrollment applications and planned market-entry or expansion strategies. The moratorium directly affects M&A activity, new provider launches, and transactions involving ownership changes. Practitioners should monitor CMS guidance for exceptions, clarifications on what constitutes a "new" enrollment, and any signals about the agency's enforcement priorities that may inform compliance posture and deal structuring going forward.