The Medicare Home Health Moratorium Hits Its November Deadline - What Non-Medical Home Care Owners Need to Know
November brings a date every home care owner should know – November 13, 2026. On that date, the nationwide Medicare enrollment moratorium on new home health agencies and hospices reaches the end of its first six-month term. CMS can let it end, lift it early, or extend it in six-month blocks. Whatever CMS decides, the outcome will shape how families find care at home in 2027.
If you run or plan to open a non-medical home care business, you may wonder how this memorandum affects you. The short answer – it changes the landscape around you, even though it does not control your own business. Here is what you need to know.
What the CMS Memorandum Says
On May 13, 2026, CMS announced a nationwide freeze on new Medicare enrollments for home health agencies (HHAs) and hospices. CMS shared the details with state survey agencies in memorandum QSO-26-11-HHA & Hospice. Under the memo:
- Medicare will not enroll new HHAs or hospices unless the Medicare contractor received the application before May 13, 2026.
- The freeze also blocks new branches, new practice locations, and certain changes in majority ownership.
- CMS does not grant exceptions for individual providers.
- Agencies that Medicare already enrolled can keep serving patients and billing Medicare.
CMS named fraud, waste, and abuse as the reason for the freeze. The agency also signaled more audits and data reviews for existing providers. You can read the full CMS moratorium memorandum on the CMS website.
The National Freeze May End, but State Limits Could Remain
The end of the nationwide moratorium does not necessarily mean enrollment restrictions will disappear everywhere. CMS has a history of targeting specific areas. Its earlier home health moratoriums started in a few metro areas and eventually covered Florida, Texas, Illinois, and Michigan statewide, and those limits stayed in place for years. CMS could let the current nationwide freeze expire while it keeps or adds restrictions in certain states or regions.
If you operate in a state CMS has targeted before, or in an area with a high rate of fraud cases, plan as if the restrictions near you could outlast the national freeze.
Why Non-Medical Home Care Sits Outside the Freeze
Non-medical home care covers services such as companionship, meal preparation, light housekeeping, errands, transportation, and supervision. Most non-medical agencies serve private-pay clients, long-term care insurance policyholders, or veterans’ programs. They do not enroll in Medicare as home health agencies, because Medicare does not pay for non-medical support on its own.
The moratorium does not stop you from opening a non-medical home care business. Your state rules still apply, though, and they vary widely:
- Some states require a full license for non-medical or companion agencies.
- Some states ask only for a registration or a certificate.
- Some states have no state-level home care license at all.
Even in a state with no license, you still need local business permits, insurance, careful hiring, and compliance with wage and tax laws. “No license” never means “no rules.”
A Gap Opens, and Families Notice
When new home health agencies cannot enter Medicare, growing communities feel the squeeze. Industry groups have warned about access problems in areas where demand keeps climbing. Families who struggle to find skilled home health help often look for other ways to keep a loved one safe at home.
Non-medical agencies can fill part of that gap. A companion who helps with meals, reminders, and safety checks gives a family real relief. Non-medical caregivers do not replace skilled nursing, and your marketing should say so clearly.
Stay inside the scope your state allows. In some states, hands-on personal care such as bathing counts as a licensed service. In others, it falls under non-medical care. Know which rule applies to you before you add a service.
Three Moves to Make Before November 13
- Confirm your service scope in writing. List every service you plan to offer and compare it to your state’s definitions. If a task crosses into medical care, drop it or find out what license it requires.
- Watch the Federal Register. CMS announces any extension there, along with any new state or regional moratoriums. If restrictions continue in your area, expect more families to ask about private-pay options.
- Tighten your paperwork. CMS has promised closer oversight of home-based care. Private-pay agencies benefit from clean care plans, accurate time records, and documented caregiver screening too. Strong records protect you if a state agency, an insurer, or a family ever asks questions.
If you bill a state Medicaid program, check your state’s notices as well. CMS encouraged states to consider their own safeguards. Ohio, for example, paused new Medicaid home health and hospice enrollments through mid-November.
Plan Your Next Step With Confidence
The moratorium creates uncertainty, but it also clarifies the path for non-medical home care. Whether your state requires a license, a simple registration, or nothing at the state level, you can build a compliant, trusted business. HomeSights Consulting helps owners understand their state’s rules, define a safe service scope, and get ready to open.
Ready to talk through your plans? Schedule a consultation with HomeSights Consulting today.