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At the National Alliance for Care at Home’s annual meeting, a CMS official discussed possible alternatives to the nationwide home health enrollment moratorium, including exceptions for established providers with strong compliance records and geographic limits. CMS has not announced a decision or published criteria, while providers await the Medicare home health final rule.
CMS is considering alternatives to a nationwide freeze on new home health agency enrollments, including a possible exception for established providers with strong compliance records and restrictions limited to specific geographic markets. The ideas were discussed at the National Alliance for Care at Home’s annual meeting in Washington, but the agency has not announced a policy, leaving providers uncertain about expansion plans and the scope of future fraud controls.
Kim Brandt, CMS deputy administrator and chief operating officer, said the agency had heard concerns from existing operators that want to expand, including into rural areas, but face enrollment restrictions. Brandt raised a potential “gold card” approach: exceptions to the moratorium for providers with strong compliance histories. Denis Fleming Jr., the Alliance’s chief government affairs officer, described the idea as a way for established operators to open additional locations while restrictions remain on new entrants.
Neither Brandt nor Fleming provided eligibility standards, and CMS has not established a gold card program. Brandt said the agency was working with its counsel’s office on possible solutions. The other option Brandt raised was to limit enrollment restrictions geographically, rather than apply a nationwide freeze. CMS could also let the moratorium expire and use other oversight tools, including approaches used in hospice, according to the report.
The discussion took place as home health providers awaited CMS’s final Medicare home health rule. The agency’s July proposal included a 2.4% aggregate payment increase and a temporary 3% reduction to the 2027 national standardized payment rate, along with proposed fraud-related measures. Those figures describe the proposal; the final rule’s terms were not yet available in the source report.
Expansion Relief Could Remain Conditional
A compliance-based exception could give some existing agencies a way to add locations without ending restrictions on all new providers. That could matter in rural communities where operators say enrollment limits are obstructing expansion and access is already strained. The impact would depend on how CMS defines an acceptable compliance record, which providers qualify and whether geographic restrictions leave local access barriers in place.
The proposed approach would not open the market equally. A gold card aimed at established agencies would not necessarily help a legitimate new provider seeking to enter a community. The report also cautions against treating the roughly 250 agencies blocked from enrollment during the moratorium as proven fraudsters: that figure refers to agencies not approved, not a count of confirmed fraudulent operators.
Changing enrollment policy would not necessarily reduce oversight. Katie Wehri, the Alliance’s vice president for regulatory affairs, quality and compliance, warned that broader proposed enrollment requirements could require providers to devote more staffing and financial resources to compliance. A narrower freeze could therefore offer expansion opportunities to some businesses while adding work for the wider provider sector.
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Moratorium Meets Payment Rule
The enrollment moratorium is part of CMS’s efforts to address fraud in home health. At the Alliance meeting, the subject came up in main-stage and breakout discussions. The report describes industry participants proposing ways to reduce the risk that compliant agencies are caught by restrictions intended to limit improper activity.
Brandt connected CMS’s anti-fraud work to provider payments, arguing that funds going to bad actors are funds unavailable to compliant providers. But the payment details remained unsettled: the July proposal paired a 2.4% aggregate increase with a temporary 3% payment-rate reduction for 2027. It also included fraud-fighting proposals, a request for information on a home health-specific wage index and discussion of expanding access to palliative care.
Hillary Loeffler, BrightSpring Health Services’ vice president of federal government relations, made a distinction relevant to the enrollment debate: a moratorium can stop new entrants, but does not by itself remove fraudulent providers already enrolled. The distinction means enrollment limits and enforcement against existing providers address different parts of the problem.
“The agency was working with its counsel’s office on potential solutions.”
— Kim Brandt, CMS deputy administrator and chief operating officer
Eligibility and Final Policy Remain Open
No policy decision has been announced. CMS has not said whether it will extend the nationwide moratorium, let it expire, restrict it to selected areas or introduce a gold card exception. The source report does not give a decision date or specify the geographic markets that might be covered.
Details of a possible gold card are also unknown, including how CMS would measure compliance, how long a provider would need a strong record, whether exceptions would apply to every type of expansion and how the agency would handle applications from new providers. The report does not establish that the proposed alternatives will be adopted.
The final home health rule was still pending in the report. Its final payment provisions and enrollment measures could differ from the July proposal, so the proposed payment figures and oversight changes should not be read as final requirements.
CMS Decision and Final Rule Pending
The next developments to watch are CMS’s decision on the enrollment moratorium and publication of the final Medicare home health rule. The report says the final rule typically arrives around Halloween, but does not confirm a release date. Providers will be looking for whether CMS adopts a nationwide extension, a geographically narrower restriction, a compliance-based exception or another approach.
Any announced policy would need to clarify its effective date and implementation details, including eligibility standards and how agencies can seek approval to expand. Until CMS provides those details, providers cannot know which locations or operators might benefit, or how enrollment policy will interact with the final payment and compliance requirements.
Key Questions
Has CMS approved a gold card program for home health agencies?
No. The gold card was discussed as a possible option. CMS has not announced a program or set eligibility criteria.
What could a gold card allow a provider to do?
The concept described at the Alliance meeting would give existing providers with strong compliance records an exception to enrollment restrictions, potentially allowing them to open additional locations.
Could CMS limit the moratorium to certain areas?
Geographic limits were raised as another possible approach. CMS has not identified any markets or confirmed that it will use geographic restrictions.
Does the figure of about 250 agencies mean 250 fraud cases?
No. In the source report, the figure refers to home health agencies not approved for enrollment during the moratorium. It is not a count of agencies proven to have committed fraud.
What was proposed for home health payments in 2027?
CMS’s July proposal included a 2.4% aggregate payment increase and a temporary 3% reduction to the 2027 national standardized payment rate. The final rule was still pending, so those proposal figures were not confirmed as final policy.
Source: homehealthcarenews.com
