CMS Suspends New Medicare Enrollments for Hospice and Home Health Agencies
The Centers for Medicare & Medicaid Services (CMS) have initiated a temporary six-month national suspension on new Medicare enrollments for hospice and home health agencies (HHAs), effective May 13. This strategic move aims to mitigate fraud, waste, and abuse in these sectors, identified as high-risk for program integrity issues. The moratorium affects new Medicare enrollment applications, impacting transactions such as changes in ownership, establishment of new practice locations, and addition of provider types.
CMS has highlighted the extensive scope of this measure due to concerns over billing practices and organizational structures within the hospice and home health domains. Issues include rapid spikes in hospice enrollments in states like Arizona, California, Nevada, and Texas, and allegations of agencies opening, maximizing billing until nearing Medicare caps, then shutting down and reopening under different guises. The occurrence of multiple HHAs operating from a single address further justifies CMS's decision for the moratorium.
Hospice and home health providers must reassess their strategies in response to these developments. Notably, changes of ownership are permissible without new Medicare enrollment, following CMS exemptions. Enrollment applications submitted before May 13 remain in process, providing they were timely and meet the established criteria.
Existing providers can update their current Medicare details, such as contact information and personnel changes, without triggering the need for new enrollment during this period. However, launching new practice locations or branches demands careful evaluation, as these are treated as initial enrollments and thus subject to the moratorium. Providers are reminded that state licensing and federal Medicare enrollment are separate processes, with state approval not overriding the federal moratorium for new enrollments.
CMS's moratorium could extend to include state-level Medicaid restrictions, mirroring federal actions and affecting provider operations. New administrative sites potentially classified as new locations must adhere to CMS's operational and reporting standards, ensuring compliance to avoid unnecessary enrollment hassles. With past examples of moratoria lasting several years, vigilance over Federal Register and CMS announcements remains essential for providers.
Lastly, CMS has clarified that despite previous regulatory language suggesting restrictions, telehealth for recertifications remains available for already enrolled hospice agencies. Providers are advised to stay informed on this and any further CMS guidance regarding telehealth and related practices throughout the moratorium.