Law Firm Assesses Six Months of CMS Home Health Enrollment Moratorium
In a client alert, Arnall Golden Gregory LLP reviews the first six months of CMS's enrollment moratorium on home health and hospice agencies, imposed in May 2026 under the agency's CRUSH anti-fraud initiative. The firm examines how the moratorium has affected provider enrollment, M&A transactions, and agency growth in the sector, addressing industry concerns raised when the policy was first announced. The analysis covers practical impacts on providers and investors navigating the enrollment freeze. No new CMS action is reported; the piece is a retrospective legal analysis of an existing policy.
Home health and hospice providers and prospective acquirers need to understand how the moratorium is being applied in practice to plan enrollment, transactions, and compliance strategy.
LTSS
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