• videocam Live Webinar with Live Q&A
  • calendar_month July 8, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Health
  • schedule 90 minutes

CMS Nationwide Moratoria on New Hospice and Home Health Medicare Enrollments: Covered Entities, Industry Impact

Heightened Transactional, Operational, and Enforcement Risks

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$252.45
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Discount expires 6/24/26

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About the Course

Introduction

This CLE webinar will examine the six-month moratoria recently enacted by CMS on new Medicare enrollments for hospice and home health agencies (HHAs). The panel will discuss the moratoria scope and impact on the healthcare industry including current and future healthcare transactions. The panel will also offer best practices for helping clients navigate the moratoria.

Description

CMS recently enacted nationwide six-month moratoria on new Medicare enrollments for hospice and HHAs. The agency cites concern over fraud, waste, and abuse as the reason behind the moratoria and describes more stringent enforcement measures to be enacted in an attempt to eliminate fraud in this sector.

The moratoria affect not only new enrollments, but also the addition of new branches or practice locations. The moratoria may also apply to certain changes in location and certain transactions and changes in ownership.

Counsel and clients should understand the full impact of the moratoria on healthcare transactions, operations, and finances. For example, pending enrollment applications received by a Medicare Administrative Contractor prior to the effective date of May 13, 2026 should not be affected by the moratoria. However, entities planning new hospice or HHA operations should treat those plans as suspended, which may then impact deals already in progress. And even where a transaction may remain viable during the moratoria period, enhanced due diligence of the target's compliance history may be in order given the heightened scrutiny and enforcement activity expected.

Furthermore, while the moratoria are aimed at hospice and HHAs, the impact may have ripple effects throughout the healthcare industry as many hospitals and healthcare providers rely on these organizations in operational support roles such as for discharge planning, continuity of care, post-acute services, and end-of-life care.

Listen as our authoritative panel of healthcare attorneys examines the CMS moratoria and the potential impact on the healthcare industry. The panel will discuss the moratoria scope, address how current and future transactions may be affected, and offer best practices for navigating the new moratoria and heightened enforcement activity.

Presented By

Jane Elizabeth Feist
Partner
Holland & Knight LLP

Ms. Feist advises hospitals, health systems, outpatient services providers, behavioral services providers, healthcare investors and specialty lenders on the intersection of federal and state regulations and transactional matters. Her practice focuses on federal and state fraud and abuse matters, including Stark, anti-kickback laws, and the False Claims Act and Medicare/Medicaid enrollment. Additionally, Ms. Feist provides counsel on the development and implementation of compliance programs and policies, and she advises clients on Health Insurance Portability and Accountability Act (HIPAA) and patient privacy issues.

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Adam L. Royal
Partner
Husch Blackwell LLP

Mr. Royal draws on his deep understanding of healthcare industry regulation and corporate transactions to help clients tackle a range of legal and business challenges. He is part of the firm’s Hospice & Palliative Care Team and routinely advises clients on regulatory compliance and provides strategic advice to executives, compliance teams, and risk professionals on a range of legal, business, and governance topics. Mr. Royal has advised clients on challenges relating to the Anti-Kickback Statute, Stark Law, HIPAA, Medicare billing, and government audits and appeals. Mr. Royal’s transactional practice covers M&A and joint ventures with specific experience on the regulatory aspects of business formations and combinations in the healthcare industry, and he advises clients on healthcare contracting and negotiation.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, July 8, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Introduction: history of CMS anti-fraud measures for HHAs and hospice

II. New CMS moratoria

A. Purpose

B. Statutory authority

C. Duration; possibility of extension

D. Covered entities

E. Affected enrollments

F. Heightened scrutiny and increased enforcement activity

III. Healthcare industry impact

A. Current and planned transactions

B. Operations

C. Financial concerns

D. Ripple effects on other providers

IV. Best practices for navigating the moratoria

The panel will review these and other important issues:

  • What is the purpose behind the new CMS moratoria for new hospice and HHA enrollments in Medicare?
  • What heightened enforcement activity may be expected?
  • What effect may the moratoria have on current and future healthcare transactions? What heightened due diligence may be required as part of these transactions? 
  • What ripple effects may the moratoria have on the healthcare industry beyond hospice and HHA Medicare enrollment?