Federal and Ohio Medicaid Enrollment Moratoriums: Vital Information for Home-Based Care Providers

The regulatory landscape for home-based care providers continues to evolve, and recent actions by the Centers for Medicare & Medicaid Services (CMS) and the State of Ohio are creating new challenges for organizations seeking to enter the market.

In May 2026, CMS announced a nationwide enrollment moratorium on new Medicare enrollments for Home Health Agencies (HHAs) and Hospice providers. Shortly thereafter, Ohio implemented its own Medicaid enrollment moratorium affecting several provider categories. Together, these actions signal increased regulatory scrutiny of the post-acute care industry and may serve as a blueprint for additional state-level restrictions across the country.

Understanding the Federal Medicare Moratorium

Effective May 13, 2026, CMS imposed a six-month nationwide enrollment moratorium on new Medicare enrollments for:

• Home Health Agencies (HHAs)
• Hospice providers

The moratorium is scheduled to remain in effect through November 13, 2026, unless CMS determines an extension is warranted.

According to CMS, the action is part of a broader initiative to combat what the agency describes as significant fraud, waste, and abuse within certain healthcare sectors.  

For providers considering Medicare participation, the impact is straightforward: no new HHAs or hospice organizations can enroll in Medicare during the moratorium period.

What the Federal Moratorium Does Not Cover

While federal action has generated considerable attention, it is important to understand its limitations.

The Medicare enrollment moratorium does not automatically apply to:

• Medicaid providers
• Children's Health Insurance Program (CHIP) providers
• Existing enrolled Medicare providers
• Certain approved ownership changes or provider transactions, subject to CMS review

Because Medicaid programs are administered at the state level, each state retains authority over its own provider enrollment policies. However, CMS has strongly encouraged states to evaluate whether similar restrictions should be implemented within their Medicaid programs.

‍Ohio Acts
On May 14, 2026, just one day after the federal announcement, Ohio implemented its own Medicaid enrollment moratorium affecting specific provider types within the home health and hospice sectors.

The Ohio moratorium applies to eight provider classifications associated with home health and hospice services and is scheduled to remain in effect through November 14, 2026.
As a result, organizations seeking to establish new Medicaid provider enrollments within these affected categories in Ohio may encounter enrollment restrictions during the moratorium period.

For providers evaluating expansion opportunities, this development underscores the importance of monitoring both federal and state regulatory activity, as state actions may differ significantly from federal policy.

Why This Matters for Providers
These moratoria represent more than temporary enrollment restrictions. They reflect a broader regulatory trend toward increased oversight, enhanced program integrity measures, and heightened scrutiny of provider enrollment processes.

Organizations planning to launch, acquire, or expand home health and hospice operations should carefully evaluate:

• Market Entry Timelines: Providers entering new markets may experience delays in obtaining Medicare or Medicaid participation, potentially impacting revenue projections and operational planning. ‍
• Transaction Due Diligence: Acquisitions and ownership transfers require careful review to determine how enrollment restrictions may affect licensing, credentialing, and payer participation. ‍
• Multi-State Expansion Strategies: As CMS continues to encourage states to adopt similar measures, providers operating across multiple states should closely monitor emerging enrollment restrictions and regulatory developments. ‍
• Compliance Readiness: Regulators are increasingly focused on fraud prevention and program integrity. Strong compliance programs, documentation standards, and operational controls will become even more important as scrutiny increases.

Could Other States Follow?
Ohio may be the first state to respond to CMS's encouragement, but it is unlikely to be the last.

CMS has signaled a growing emphasis on Medicaid program oversight and has increased pressure on states to investigate suspected fraud and abuse. Given this environment, additional states may consider implementing enrollment moratoria or enhanced screening requirements for providers operating in high-risk sectors.

Providers should remain vigilant and maintain regular communication with licensing agencies, Medicaid programs, and industry associations to stay informed about potential changes.

How Paradigm Can Help

Enrollment restrictions create uncertainty, but they also reinforce the importance of proactive planning and compliance management.

Whether your organization is pursuing Medicare or Medicaid enrollment, expanding into new markets, acquiring an existing agency, or navigating state-specific requirements, Paradigm's credentialing, compliance, and revenue cycle experts can help you understand the regulatory landscape and develop a strategy that supports sustainable growth.

As federal and state oversight continues to evolve, staying informed and prepared will be critical to protecting your organization's expansion plans and long-term success.

Need guidance on provider enrollment, credentialing, or compliance strategy? Contact Paradigm to discuss how our team can help your organization navigate these changing regulatory requirements.