On May 13, 2026, CMS did something it had not done in more than six years: it stopped letting anyone new into Medicare home health and hospice. Not in a county, not in a state, nationwide. If you own a Medicare-certified agency today, you own something that cannot currently be created. That was the story in May, and we covered it then. The story now is different, and it has a date on it. The freeze was imposed for six months, which means CMS reaches its first decision point on it around November 13, 2026. Between now and then, owners who have been circling a sale are making a decision whether they realize it or not.

What has changed since May is not the moratorium itself. It is everything around it: CMS has proposed rule changes that would tighten how the freeze works, has proposed a CY 2027 payment picture that is more complicated than the headline suggests, and has left a comment window that closes on August 31, 2026. This piece is about what those three things mean for an owner deciding whether to move now or wait.

What exactly is frozen, and until when?

Two Federal Register notices published on May 15, 2026 imposed the freeze: a nationwide temporary moratorium on the Medicare enrollment of home health agencies and a companion notice covering hospices. Both are described in their own summaries as a 6-month nationwide moratorium, and both state that the moratorium is effective May 13, 2026.

Under 42 CFR 424.570(b), a temporary enrollment moratorium remains in effect for six months and may be extended in six-month increments. CMS evaluates whether to extend or lift it before the end of each period, and any extension is announced by a notice published in the Federal Register. As of the last week of August 2026, no extension notice has been published. That does not mean one is not coming. It means the decision has not been made public yet, and the initial period runs out in November.

Will the freeze lift in November?

Nobody outside CMS knows, and any advisor who tells you otherwise is guessing. But there is a documented precedent, and it is worth knowing before you assume November brings relief.

The May 2026 notice recounts the history of the last time CMS used this authority. A moratorium imposed in July 2013 on home health agencies in Miami-Dade and Cook Counties was extended in February 2014, again in August 2014, February 2015, July 2015, February 2016, and August 2016, expanded to statewide in Florida, Illinois, Michigan and Texas along the way, then extended again in January 2017 and July 2017. By CMS’s own account in that notice, the original 2013 moratorium, after being extended and revised several times, expired on January 30, 2019. A six-month program integrity action ran for more than five years.

History is not a forecast. But planning your exit around the assumption that the window closes in November, or around the assumption that it definitely stays open, are both bets. The more useful question is what the freeze does to your agency’s position either way, because on that the answer is clearer.

Why does an enrollment freeze make an existing agency more valuable?

Because it removes the alternative. In an ordinary market, a buyer who wants to operate a Medicare-certified home health agency in a given metro has two paths: buy one, or start one and go through enrollment and certification. The second path is slow and unglamorous, but it exists, and its existence disciplines what buyers will pay for the first path.

While a nationwide moratorium is in force, the second path is closed. For a buyer with capital and a timeline, acquiring an existing certified agency is not the cheaper option, it is the only option. That does not entitle any particular seller to any particular number, and it does not make a weak agency a good one. What it does is concentrate the entire pool of would-be entrants onto the existing supply of certified agencies, and that supply is fixed for as long as the freeze runs.

The corollary matters just as much: this advantage is not permanent and it is not evenly distributed. It lasts as long as the freeze lasts, and it accrues to agencies that can actually be transferred cleanly. Which brings us to the part most owners get wrong.

Does the moratorium block the sale of an existing agency?

Usually no, sometimes yes, and the difference is deal structure rather than anything about your agency’s quality.

Under 42 CFR 424.570(a)(1)(iii), a temporary moratorium does not apply to changes in practice location, changes in provider information such as a phone number, or changes in ownership. That last exception carries a parenthetical that is the whole ballgame: it excludes changes in ownership of home health agencies that would require an initial enrollment. If a transaction is structured so that the buyer has to enroll as a new provider, that new enrollment runs straight into the moratorium.

In practice this is where the CMS change in majority ownership rules and the 36-month rule intersect with the freeze. A change in majority ownership that requires the buyer to enroll as a new provider under 42 CFR 424.550(b) or 424.551 is not a routine ownership update; it is an initial enrollment, and initial enrollments are what the moratorium stops. An agency that is past its seasoning window and can transfer through an ownership change that CMS treats as a change of information, rather than as a new enrollment, is in a completely different position from one that cannot.

This is not a detail to discover in diligence. It determines whether a deal can close at all, and it should be established before a listing goes to market, not after a buyer is at the table.

What has CMS proposed to change about the freeze?

This is the genuinely new development since May, and it has had far less attention than the original announcement. The CY 2027 Home Health Prospective Payment System proposed rule, published July 6, 2026, does not only set payment rates. It also proposes changes to Medicare provider enrollment policy, including the moratorium rules themselves. CMS states plainly in that rule that since restarting the moratorium process in 2026 after more than six years, it has seen several issues it believes must be addressed in regulation.

Two of the proposals matter directly to anyone contemplating a transaction:

• The ownership-change carve-out would be written more broadly. CMS proposes to change the parenthetical in 424.570(a)(1)(iii)(C) from one that names only home health agencies to one covering changes in ownership that require an initial enrollment, such as, but not limited to, an HHA, hospice, or DMEPOS supplier change in majority ownership under 424.550(b) or 424.551. CMS describes this as conforming to other regulations and codifying existing policy, that hospices, like HHAs, must enroll as a new provider after a non-exempt change in majority ownership and are therefore subject to the moratorium. For hospice owners in particular, this removes any argument that the narrower existing text left them outside the rule.
• The effective date would move earlier. CMS proposes that the date a moratorium is imposed is its effective date, defined as the date the notice was filed for public inspection at the Office of the Federal Register, rather than the later publication date. The rule explains the reasoning candidly: using the publication date would give affected providers several days to file applications to beat the deadline, which would partly obstruct the moratorium’s goal and could produce a rush of new applicants. Anyone planning around a future moratorium announcement should understand there is no longer expected to be a gap to run through.

The comment period on that proposed rule closes August 31, 2026. Owners and operators who want to be heard on the enrollment provisions have a very short runway, and comments are submitted through the Federal Register docket, not through a trade association alone.

What does the CY 2027 payment proposal actually do to home health revenue?

The headline number looks fine. Underneath it there is an overhang that any buyer’s financial model will account for, and that sellers should understand before they hear it in a negotiation.

CMS proposes a CY 2027 home health payment update of 2.1 percent, built from an estimated 3.1 percent market basket increase reduced by a 1.0 percentage point productivity adjustment. In aggregate, the agency projects payments in CY 2027 would rise 2.4 percent, a net transfer of $420 million above a projected CY 2026 baseline of $17.575 billion, bringing total projected spending to roughly $18 billion.

That 2.4 percent is a year-over-year figure, and it is easy to misread. It does not mean rates are being restored. CMS is also proposing to continue a 3.0 percent temporary adjustment that claws back what it treats as prior overpayments. The reason that cut does not show up in the year-over-year math is stated explicitly in the rule: the aggregate impact of the proposed temporary adjustment equals zero percent because both the CY 2026 and CY 2027 payment rates would include a 3.0 percent temporary adjustment. In other words, the reduction is already inside today’s rates, and CMS proposes to keep it there for another year.

The scale of what remains outstanding is the number worth carrying into any valuation conversation. CMS estimates the proposed 3.0 percent reduction would collect approximately $500 million in CY 2027, which it describes as about 10 percent of a total $4.9 billion. The agency is explicit that it may propose additional temporary adjustments in future rulemaking. Separately, the rule shows that a permanent prospective adjustment of negative 5.043 percent to the CY 2027 rate would be required to fully offset the increases in estimated aggregate expenditures for CY 2020 through CY 2025, an adjustment CMS has so far applied only in part.

Read together: a modest annual increase, layered on a base that already carries a recoupment cut, with roughly ninety percent of the claimed overpayment still uncollected and a much larger permanent adjustment sitting on the shelf. Sophisticated buyers price that risk. Owners who can speak to it credibly negotiate better than owners who are hearing it for the first time across the table.

Who is buying home health and hospice agencies right now?

• Existing operators expanding geographically. The most active category during a freeze. An operator who wants to enter a new state cannot start an agency there, so acquisition becomes the only entry route.
• Private equity platforms and their portfolio companies. Buying scale, coverage, and certified licenses. Their diligence is the most structured and their questions about the temporary adjustment and the permanent adjustment will be the sharpest.
• Regional strategics and health systems. Buying referral control and post-acute continuity in a defined service area, often paying for fit rather than for size.
• Individual and physician buyers. Active at the smaller end, frequently financing through SBA-eligible structures, and often the buyers most affected by whether a transaction triggers a new enrollment.

You will not find a valuation multiple in this article. Home health and hospice agencies trade across a range that moves with census stability, payer mix, survey and compliance history, geography, seasoning, and whether the entity can transfer without a new enrollment. Any single number published without your financials in front of us would be exactly the sort of unsourced claim this firm does not make. What we can say is that the drivers above decide where a specific agency sits inside whatever range the market supports.

What should an owner do between now and November?

• Establish your transfer path first. Determine, with counsel, whether a sale of your agency would require the buyer to enroll as a new provider. That single answer changes your buyer pool, your timeline, and in some cases whether a deal is possible during a moratorium at all.
• Confirm your seasoning position. Know your certification date and where you stand against the change in majority ownership rules. Do not rely on the date on a PTAN letter as a proxy for the date CMS will treat as controlling.
• Get the compliance file in order. Survey history, plans of correction, documentation integrity, and any payer audit activity. In a program integrity environment, this is not paperwork, it is the asset.
• Build the payment story. Be able to explain to a buyer how the temporary adjustment affects your revenue per period and what your margin looks like with it in place, because the buyer’s model will include it whether or not you raise it.
• Clean the financials. Separate owner expenses, normalize related-party arrangements, and reconcile revenue to claims data so the earnings a buyer sees are earnings you can prove.
• Decide deliberately, not by drift. Waiting is a legitimate choice. Waiting without deciding is how owners end up selling into whatever conditions happen to exist when they finally run out of patience.

Where this leaves owners

Holding an asset that the federal government has temporarily made impossible to replicate, in a payment environment that is stable this year and unresolved beyond it. Those two facts pull in opposite directions, and that tension is precisely why this period rewards owners who have done the preparation and punishes those who have not. The freeze concentrates demand onto agencies that can transfer cleanly. The payment overhang means buyers will underwrite carefully. An agency that is ready for both conversations is in the strongest position the sector has offered in some time.

Vallexa Advisors represents home health, hospice, and home care owners through confidential, success-fee sale processes. If you own an agency and want to understand what the current environment means for your specific situation, start with our home health agency valuation and sale overview or our hospice sale process overview, or contact us for a confidential conversation. Buyers can review current inventory, including a Virginia Medicare-certified home health agency, a San Diego home health agency that is 36-month exempt, and a Phoenix, Arizona Medicare and Medicaid certified agency, or join our buyer network to see opportunities first.

This article summarizes federal rules and proposals as published in the Federal Register and is general information, not legal, tax, or regulatory advice. Enrollment and change-of-ownership questions turn on facts specific to your agency and should be reviewed with qualified counsel.

Frequently asked questions about the enrollment moratorium and selling an agency