May 2026 Hospice & Home Health Enrollment Moratorium: Cost-Report Implications for Existing Providers

§A — What the moratorium does

On May 13, 2026, CMS announced a nationwide six-month temporary moratorium on Medicare enrollment of new Home Health Agencies and Hospices, framed as part of an aggressive nationwide crackdown on fraud in these provider categories. The formal legal notices were published in the Federal Register on May 15 (HHA: notice 2026-09717; Hospice: notice 2026-09718).

The moratorium applies to:

• Applications for initial Medicare enrollment as an HHA or Hospice — new providers cannot enroll in Medicare during the moratorium period.
• Certain changes in majority ownership — CMS identifies majority-ownership transfers as a vector frequently used to obscure control by bad actors. Specific transactions in this category are also restricted during the moratorium.

It does not apply to:

• Currently-enrolled HHAs or hospices providing services to Medicare beneficiaries. Existing operations continue normally.
• Beneficiary access — CMS has stated the moratorium is not intended to impact patients' access to Medicare-covered home health or hospice services.

The statutory basis is Section 1866(j)(7) of the Social Security Act, implemented via 42 CFR § 424.570, which allows CMS to impose temporary enrollment moratoria where it determines there is a significant potential for fraud, waste, or abuse. The Federal Register notices may also describe limited exceptions in cases where access to care would otherwise be jeopardized; the operative scope and exception mechanism are described in the notices themselves and should be consulted directly for case-specific questions.

§B — Why it matters for existing providers

For a currently-enrolled HHA or Hospice, the moratorium changes nothing on the cost-report itself. The same forms apply (CMS-1728-20 for HHA, CMS-1984-14 for Hospice). The same five-month filing deadline applies (42 CFR § 413.24(f)(2)). The same step-down cost allocation methodology applies. The same Provider Reimbursement Manual instructions apply.

What changes is the enforcement environment. CMS has explicitly framed the moratorium period as a window for intensified investigations, advanced data analytics, and accelerated removal of providers suspected of committing fraud. The program-integrity attention historically directed at new-enrollment screening is being redeployed toward existing providers — pattern analysis on billing, cost-report consistency, and statistical outliers.

Two practical consequences follow:

• MAC oversight may intensify on existing-provider cost reports. The Medicare Administrative Contractor review cycle (desk reviews, Targeted Probe and Educate, and Notice of Program Reimbursement issuance) operates on the same regulatory clock, but resource allocation to these activities may shift upward during the moratorium period.
• Audit-trail documentation becomes more load-bearing. Where pre-moratorium cost reports might have cleared MAC review on the basis of consistency with prior-year filings, the data-analytics-driven scrutiny CMS has described emphasizes why a number is the number — the formula, the inputs, the trial-balance source. Cost reports that can answer the "trace this number back" question quickly are likely to clear review faster than reports that cannot.

§C — Practical implications for cost reporting

The cost-finding standard under 42 CFR § 413.24 has always required providers to maintain "adequate cost data" such that the cost of services furnished to Medicare beneficiaries can be accurately determined. The moratorium does not change that standard. What it changes is the probability that the underlying records will be examined and the depth of any examination.

The cost-report mechanics most likely to face elevated scrutiny during the moratorium period:

• Trial-balance to cost-center mapping (Worksheet A reclassifications and adjustments). Adjustment entries on Worksheet A-6 and A-8 should be traceable to the general-ledger detail that supports them. Reclassifications that lack a written rationale or a corresponding source document are the typical first issue in a desk review.
• Statistical bases for step-down allocation (Worksheet B-1). The statistical bases that drive cost-center cross-allocation (square footage, FTE hours, patient days) should be reproducible from underlying timesheets, occupancy records, or census data. Round numbers without supporting documentation invite further inquiry.
• Visit and patient-day counts (Worksheet S-3 Part IV for HHA; Worksheet S-1 Part III for Hospice). Counts that drive PPS settlement and per-diem payment totals should reconcile to clinical documentation systems and billing records.
• Related-party transactions (Worksheet A-8-1 for HHA; corresponding hospice surface). CMS's anti-fraud framing specifically references obscured control via majority-ownership transactions; related-party disclosures on the cost report should be complete, current, and consistent with provider-enrollment records.

§D — What existing providers should do

A short checklist for existing-provider cost-report preparers during the moratorium period:

1. Tighten audit-trail documentation. For each customer-visible number on the cost report, the underlying formula, inputs, and source records should be retrievable in one step. The 42 CFR § 413.24 standard requires it; the moratorium-era environment makes it operationally load-bearing.
2. Review Worksheet A-8-1 related-party disclosures against current ownership records. Drift between cost-report disclosures and provider-enrollment Form 855A data is the kind of inconsistency that data-analytics screening surfaces immediately.
3. Re-verify statistical bases on Worksheet B-1. If your step-down allocation uses prior-year statistics, pull current-year occupancy / FTE / patient-day data and confirm the bases still reflect the operational reality.
4. Run a pre-submission self-audit. A structured pre-submission walk-through — cross-worksheet reconciliation, reasonableness checks against historical HCRIS data, related-party verification — catches the most common findings before the MAC does. Per 42 CFR § 413.24, the documentation that supports each filed number is the provider's responsibility regardless of who prepares the report.
5. Coordinate with your authorized representative. Your authorized representative signs the cost report and attests to its accuracy. In a moratorium-era enforcement environment, the documentation that supports the attestation matters more than the attestation itself. Make sure the signer has direct access to the supporting records.

We're building cost-report preparation tooling that handles the trial-balance-to-cost-center mapping, the step-down allocation, and the audit-trail emission so every customer-visible number traces back to its formula and inputs. Not a CMS-approved vendor yet — pursuing that designation through the Office of Financial Management Part A Cost Report Division. Whether you use a CPA firm, a billing agency, or an independent consultant for filing, the documentation standard is the same and the moratorium-era scrutiny applies regardless of preparer.

§E — Frequently asked questions