Today, we’re discussing one of the biggest developments the home health and hospice industry has seen in years. On May 13, CMS announced a federal moratorium that temporarily halts new home health and hospice providers from entering the Medicare certification process.
Providers that were already in the Medicare certification process and had an application accepted by the Medicare contractor will still be allowed to continue moving through the process. However, CMS will not accept any new 855 applications for Medicare certification during the next six months. In addition, providers will not be permitted to open new branch locations during the moratorium period.
In addition, CMS released a question-and-answer document alongside the moratorium announcement. The FAQ clarified that hospices will still be permitted to conduct telehealth face-to-face encounters during the temporary moratorium period.
Earlier this year, the Consolidated Appropriations Act of 2026 extended telehealth face-to-face encounters for both home health and hospice providers through December 2027. However, the legislation also stated that hospices operating in states under a federal moratorium would not be allowed to use telehealth for those encounters. The newly released FAQ specifically confirms that telehealth face-to-face encounters will continue to be allowed despite this temporary moratorium.
At this time, the moratorium is scheduled to remain in effect for six months. There is also an expectation that, once this initial period ends, CMS could implement longer-term moratoriums in multiple states across the country.
Along with the moratorium announcement, CMS also indicated that existing home health and hospice providers should expect increased oversight and scrutiny. From our perspective, that likely means a rise in medical review activity across the board, including SMRC audits, UPIC audits, Targeted Probe and Educate reviews, RAC audits, and other types of contractor-led audits. Overall, providers should be prepared for a higher volume of compliance and documentation reviews moving forward.
Healthcare Provider Solutions is prepared to help organizations take a proactive approach to documentation compliance and audit readiness. If your agency is selected for additional medical review activity, we can assist in making sure your charts are properly prepared and positioned for review.
Our team routinely works with home health and hospice providers nationwide during ADRs, SMRC audits, UPIC audits, and other medical review processes. We are experienced in conducting detailed chart reviews and can help identify potential denial risks, giving your organization a clearer understanding of how your documentation may perform under medical review scrutiny.
It’s important to note that if your home health or hospice agency was already in the survey process when the moratorium took effect and is still awaiting a provider number, you should anticipate additional scrutiny once billing begins. This may include Additional Development Requests (ADRs), meaning your charts could be requested for medical review before claims are processed and payment is issued.
During this period of increased oversight, it is more important than ever for agencies to remain diligent with patient eligibility and documentation standards. Home health and hospice providers should ensure that every patient admitted meets all applicable qualification requirements, including terminal illness criteria for hospice patients and homebound status and medical necessity requirements for home health patients.
Agencies should also make certain that clinical staff are thoroughly prepared to document the care being provided and the ongoing eligibility of each patient. Accurate, complete, and timely documentation will be critical in supporting continued care and withstanding heightened medical review scrutiny.
Healthcare Provider Solutions helps home health and hospice agencies stay audit-ready through proactive documentation reviews, compliance support, and expert guidance during ADRs, SMRC audits, UPIC audits, and other medical review processes. Should you require Medical Review assistance, please reach out to us.
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