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Moratorium Mode: CMS Freeze on Home Health & Hospice Enrollment · Home Health Revealed (+Palliative and Hospice)

• 0:03
  Welcome to Home Health Revealed, the podcast for home health and hospice leaders who want to stay connected to the industry and ahead of what's next. Welcome back to Home Health Revealed. I am Hannah Vail, your host and today we are going to talk about the moratorium. We're about a month in, we've been talking and thinking about this and I just want to get to have a conversation and review some of the things the FAQs that have come out. So let's talk about what the CMS Home Health and Hospice moratorium really means for providers. This is not a policy change that we can ignore because it affects enrollment, ownership changes, branch expansion, and transaction planning. Let's start with what the moratorium is. A moratorium is a temporary halt on enrolling new providers or suppliers in a specific category.
• 0:56
  CMS uses moratoria as a program integrity tool when it sees a significant risk of fraud, waste and abuse. In this case, CMS has applied that authority to home health agencies and hospices nationwide.
• 1:12
  Starting on the effective date, CMS will not enroll new home health agencies or hospice providers into Medicare. The moratorium applies to initial enrollment applications and it also includes certain non exempt changes and majority ownership. If an application is submitted during the moratorium, it will be denied, so you might as well not waste your time and it must be resubmitted after the moratorium lifts. Let's talk about what is not affected with this moratorium. Existing enrolled providers can generally keep participating in Medicare, keep submitting claims, and complete ongoing compliance tasks per usual. That means routine changes like updates to enrollment information, revalidation obligations still matter. Things like updating phone numbers, changes like that still need to be submitted. That is not affected. The moratorium is aimed at new enrollments, not at shutting down currently operating agencies.
• 2:16
  One of the biggest operational issues is expansion. CMS says you cannot add a new practice branch, new location, new satellite office, or expand during the moratorium for agencies in growth mode. That means some planned expansions may need to be reviewed carefully before a request is submitted. Do keep in mind and I'll talk in a second about appeals and exemptions. Ownership transactions also deserve some special attention under this moratorium.
• 2:49
  Under the CMS rules, certain majority ownership changes within 36 months of initial enrollment or the most recent qualifying ownership change can trigger a new enrollment requirement. If that happens during the moratorium, the new enrollment path is going to be blocked. CMS does allow an administrative appeal if a denial is based on the moratorium, but the appeal is very narrow. The only issue is whether the moratorium applies to that provider or supplier. CMS also states that it does not permit individual exceptions to the moratorium. If you look at the FAQ on the cms.gov website under Files, there is a document called Home health hospice moratorium FAQs. It does say providers or suppliers may use the existing appeal procedures to administratively appeal a denial of billing privileges based on the imposition of a temporary moratorium. However, the scope of such appeal would be limited solely to assessing whether the temporary moratorium applies to the provider or supplier appealing the denial. CMS regulations do not permit exceptions to a moratorium for individual providers or suppliers. So again, very narrow opportunity there for any appeals or exceptions. For Medicaid and telehealth, CMS is really leaving it to the states to decide whether to implement their own moratoriums. CMS is encouraging states to consider their own provider and geographic risks. They believe that the states know their population can consider the markets that they are serving the beneficiaries they have in their area. On the hospice side, the moratorium does not change the current telehealth flexibility for face to face recertifications for them to qualify. The big takeaway here I think is pretty simple. The moratorium is a provider enrollment and transaction issue, not a claims payment issue for existing providers. So for home health and hospice organizations the smartest step is to review your enrollment plans. Review any ownership activity and expansion timelines now before a denied application creates any kind of delay. Keep all existing enrollment information current, including including change of information and any revalidation requirements. But CMS says the moratorium does not stop ongoing compliance obligations. Agencies should expect more scrutiny, not less because CMS said it will intensify targeted investigations during the moratorium period. So that makes documentation, billing integrity and audit readiness even more important, if that's even possible. We always talk about how important it is to build an audit ready culture to have documentation integrity things that stand on their own two feet. Review your OASIS processes. Review face to face documentation episode timing. Look at your coding accuracy and denial trends so that you can spot any weak points before they attract any attention. And if your agency is pursuing expansion, the safer move right now is to redesign your plan around existing enrollment structures rather than waiting and assuming that this is going to be over in six months because we just don't know yet. So so do tighten your internal audit readiness and denial management monitoring. If you are looking for a partner to help with coding OASIS review RCM making sure claims are submitted appropriately and paid, please feel welcome to reach out to me. You can find information about health rev@healthrevpartners.com this moratorium is a strong reminder that in home health and in hospice, success is not about just staying busy with referrals. It is about being prepared, being compliant and aligning with the right partners within the industry. Agencies that surround themselves with strong operational, clinical, legal and revenue cycle support are better positioned right now to navigate these changes, to protect their reputations and to keep moving forward with confidence. We'll talk to you soon.