The Home Health and Hospice Moratorium at Six Months: What CMS’ Anti-Fraud CRUSH Initiative Has Meant for Providers

Key Takeaways

• CMS’ home health and hospice enrollment moratorium points to a broader anti-fraud enforcement strategy. Providers should prepare for continued enrollment scrutiny even if the moratorium expires.
• CMS is expanding beyond traditional program-integrity tools by using financial intelligence, affiliations, and enhanced oversight to identify potential fraud risks.
• Home health and hospice providers should review ownership, medical director, managerial, and transaction relationships now to identify connections that could create enrollment or revocation exposure.

When the Centers for Medicare & Medicaid Services (“CMS”) imposed its unprecedented enrollment moratorium on home health and hospice agencies in May 2026, the industry response was manifold, but predictable. Would this chill legitimate M&A transactions and agency growth? Would this worsen access to care issues in rural or underserved areas? Wasn’t a nationwide freeze overkill when “fraud hotspots” were concentrated in a subset of states?

Six months later, with the moratorium’s initial term set to expire on November 13, 2026, the more pressing question for home health and hospice providers has shifted: What comes next, and are you ready for it?  At the recent AHLA Fraud and Compliance Forum in Washington, D.C. on September 22, 2026, CMS Deputy Administrator and COO Kim Brandt spoke candidly about the agency’s enforcement trajectory and suggested that the moratorium serves as the beginning, not the end, of a new enforcement posture. And the tools that CMS is deploying now should command every provider’s attention.

CMS Enforcement Results Under the Home Health and Hospice Moratorium

Brandt was direct: CMS considers the moratorium a success.  Among the highlights from the agency’s perspective, Medicare enrollment revocations were implemented for approximately 800 of the roughly 1,500 hospices operating in Los Angeles County alone, a region that has come to be considered the nation’s epicenter of hospice fraud. In total, CMS revoked 1,413 providers and suppliers in just the first quarter of 2026, a 40% surge that was the largest quarterly increase on record. And earlier this year, CMS announced that over 200 hospices in the initial four states identified for the Provisional Period of Enhanced Oversight (“PPEO”) audit initiative had lost their Medicare enrollment, while also confirming expansion of PPEO to two more states: Georgia and Ohio.

How CMS Is Expanding Home Health and Hospice Fraud Enforcement

The numbers alone paint a picture of the agency moving aggressively, and then deciding to move faster.

CMS and FinCEN Are Using Financial Data to Identify Provider Fraud Risks

Perhaps the most striking development is the deepening partnership between CMS and the Department of the Treasury. In a September 9, 2026, announcement, the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) revealed that it had identified approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud, drawn from thousands of Bank Secrecy Act reports filed by financial institutions in just one year. Home health care businesses were the most frequently identified provider type in those reports, appearing in 20% of all health care fraud-related filings. The collaboration between CMS and the Treasury may not be a one-time occurrence but likely represents an expansion of the agency’s enforcement toolkit.

Brandt also described how CMS is leveraging Treasury’s financial crimes data in ways that traditional program integrity tools never could. One striking example: financial data revealed a single bank account tied to hundreds of hospices in LA County — a connection that CMS would not have been able to identify through its own enrollment data or standard affiliation analysis. CMS is also cross-referencing providers with IRS compliance issues, based on the theory that individuals with tax problems may have broader compliance deficiencies.

Medicare Enrollment Affiliations Create Growing Revocation Risk

While the moratorium has dominated the headlines, CMS’ less-publicized enforcement actions are what home health and hospice providers should be looking to next. Providers need to take a closer look at their medical directors and their affiliations because CMS is using its affiliation revocation authority with increasing frequency. According to the Congressional Research Service, affiliation-based revocations accounted for more than one-quarter of all Medicare hospice revocations in 2025, with every single one carrying 10-year re-enrollment bar. If a medical director or a key member with “managerial control” has a history with a revoked provider, that connection alone may be enough to jeopardize the enrollment of other providers through affiliation. The risk is not theoretical. The revocation actions are happening now.

Industry Groups Challenge the Moratorium’s Impact on Providers and M&A

Any retrospective of the moratorium would be incomplete without acknowledgement of the financial, operational, and reputational costs on legitimate home health and hospice providers. The National Alliance for Care at Home’s letter to CMS on September 4, 2026, requested that the moratorium be allowed to expire, documenting concrete unintended consequences, such as healthcare affiliations delayed or abandoned, hospices with newly constructed inpatient units sitting empty, and struggling providers facing closure because acquisition transactions could not proceed. LeadingAge echoed such concerns in its own letter to the agency, noting that members who had made substantial investments in new services for their communities have been covering overhead costs while waiting for the moratorium to lift. Both organizations urged a shift from a national moratorium to targeted enforcement that reaches bad actors without freezing out legitimate providers.

Importantly, Brandt confirmed that CMS does not need to give 60 days’ notice to extend or end the moratorium. As a result, whether the moratorium extends, expires, or is replaced with something else remains an open question, but CMS is evaluating its next steps now. If you have questions about how the moratorium or CMS’ evolving enforcement posture may affect your organization, please contact AGG Healthcare partner Lanchi Bombalier.