CMS Moratorium & Increased Oversight: How Amity Healthcare Group Can Help

On May 13, 2026, CMS announced a nationwide six-month moratorium on new Medicare enrollment for home health and hospice providers as part of one of the agency’s most aggressive fraud-prevention initiatives to date.

CMS Announces Aggressive Nationwide Crackdown on Fraud with Six-Month Hospice and Home Health Agency Enrollment Moratoria | CMS

Federal Register: Medicare, Medicaid, and Children’s Health Insurance Programs: Announcement of Nationwide Temporary Moratoria on Enrollment of Home Health Agencies (HHAs)

While this moratorium does not immediately directly affect currently enrolled providers, it signals a clear shift: CMS is increasing scrutiny on existing agencies, accelerating investigations, and taking action against providers who cannot demonstrate compliance, operational integrity, and clinical accuracy.

While CMS’ primary intent is to identify providers operating outside regulatory expectations, the increased enforcement environment affects all agencies.

What does this mean for your agency?

1. For Existing Agencies: CMS and its contractors are heavily ramping up their oversight. You should anticipate an increase in unannounced site visits, more rigorous auditing (including TPE, SMRC, and UPIC audits), and stricter enforcement of Medicare Conditions of Participation.
2. For Agencies Enrolling or Expanding: The newly announced six-month enrollment measures will result in a minimum 6 month delay of processing times for new enrollments and likely heightened scrutiny for, revalidations, changes of ownership (CHOWs), location changes, management changes, and other changes you make to your 855A. CMS will be looking closely at ownership structures and operational readiness.
3. All provider agencies must demonstrate legitimacy, compliance, and operational transparency continuously.

Recommended next steps:

• Survey Readiness: start survey readiness efforts regardless of where you are in your survey cycle.
• QAPI Program Review: tighten up your QAPI Program efforts and analyze your data regularly and frequently. Increase your chart reviews, if needed. Make joint visits with your staff to analyze competency and education needs.
• Clinical Operations: ensure you have good systems in place for intake, case management, and assessment and evaluation of patient satisfaction and staff satisfaction, and clinical compliance.
• Billing Audits – Conduct and analyze your billing and revenue cycle audits to ensure your practices can stand up to the scrutiny of an audit. Assess EVV compliance and alignment with the billing records.
• Operational Compliance – Review your operational systems, in alignment with regulatory compliance. Ensure adequate Governing Body involvement.
• Provider Enrollment – Sign into your PECOS account and make sure all your agency details are correct and up to date. Your management details need to be current. Know your revalidation date and complete the required revalidation in timely manner. Make sure you are billing for traditional Medicare patients and do not go more than 6 months without billing Medicare.

How can Amity Healthcare Group help?

Mock Surveys – Regulatory & Survey Readiness Support

With CMS increasing site visits, audits, and targeted investigations, agencies must ensure their operations, documentation, and quality systems can withstand scrutiny.

We will help you to:

• Validate compliance with Medicare Conditions of Participation
• Prepare for unannounced surveys and focused reviews
• Identify vulnerabilities before CMS and/or an Accreditation Organization does

QAPI Consulting – Strengthen Compliance Through Effective QAPI Program Development, Data Analysis, and Performance Improvement

• Strengthen your regulatory compliance
• Decrease your audit risk
• Have a clear picture of your clinical operational status
• Continuously improve the quality of the care you provide
• Develop corrective action guidance to reduce risk

ICD 10 Coding, OASIS Review & Clinical Documentation Accuracy

CMS is using advanced analytics to flag suspicious patterns and improper billing. Our clinical team provides:

• ICD 10 coding support
• Clinical documentation review (OASIS, POC, etc.)

Clinical Skills Competency, Training & Staff Preparedness

Clinical staff competency is directly tied to quality outcomes, patient satisfaction, and overall agency performance.

We offer:

• Initial and annual competencies for skilled nurses
• Approved home health and home care administrator/manager training programs for states of Colorado and Texas
• Continuing education accredited by IACET

It’s time to reinforce your systems, validate your documentation, and ensure your staff and processes are aligned with CMS expectations. We are here to support you through every step.

If you would like to schedule a consultation, please feel free to:

• Call us at:
  • Denver Office: 303 690 2749
  • Houston Office: 713 564 5011
• Email us at: ig@amityhealthcaregroup.com
• Schedule a 20 min. free consultation at our Contact Page