CMS's new Medicare enrollment rules: what hospices and home health agencies should know

Short answer: CMS's CY 2027 home health final rule also rewrites Medicare enrollment rules for every provider type. It adds denial and revocation grounds, gives every revocation ground a retroactive effective date, shortens the claims window after a revocation to 15 days, and lets CMS bar reapplication for up to 10 years after any denial. CMS dropped three proposals.

Key facts (as of Nov. 6, 2026) - Rule: CMS-1844-F, published in the Federal Register Nov. 9, 2026, at 91 FR 72022 (filed for public inspection Nov. 4). - Effective date: the published DATES line prints "January 4, 2026" for the enrollment changes (see below). The payment provisions take effect Jan. 1, 2027. - New hospice-specific denial grounds target medical directors and administrators (42 CFR 424.530(a)(20)). - After a revocation, claims for earlier services are due within 15 calendar days of the revocation letter date, not 60 days after the effective date (424.535(h)). - CMS did not finalize its debt-based, payment-suspension-based and "extension of revocation" proposals. - CMS estimates about $82 million a year in transfers from providers to the government, plus $15.6 million a year in signage costs.

Most coverage of the CY 2027 rule has focused on the payment math, which we cover in our final rule explainer. This story is about the other half: Section V.C, the Medicare provider enrollment provisions, which apply well beyond home health. We read the rule's summary, its comment responses and its regulatory text.

What did CMS finalize on enrollment?

CMS finalized most of what it proposed in July, with a few changes. According to the final rule, the main pieces are:

• More grounds to deny enrollment (42 CFR 424.530). New grounds cover an affiliation that poses undue risk, a practice location in the same suite as a provider whose enrollment was revoked or denied, misuse of another party's identity, and failure to follow the change-in-majority-ownership rules. Convictions for certain misdemeanors tied to sexual assault or financial misconduct within the past 10 years are also grounds.
• More grounds to revoke (424.535). CMS added revocation where an enrollment "presents a high risk of fraud, waste, or abuse" because of its location in "a limited geographic area that has an excessive number of providers and suppliers" (a)(24), and for ownership-change non-compliance (a)(25). It also reworded the false-or-misleading-information ground to cover any enrollment-related form or documentation, not only the application.
• A broader reapplication bar. CMS can currently bar reapplication for up to 10 years after a denial for false or misleading information. The rule lets it apply the bar "for any reason" under section 424.530 (f).
• Retroactive revocation dates. Under the old rule, a revocation was effective 30 days after the notice unless a listed ground made it retroactive. The new text assigns a specific effective date to each ground, usually the date of the underlying problem, such as the date a license was revoked or the date false information was submitted.
• A signage requirement. Providers and suppliers must keep "a permanent visible sign in plain view" with their hours of operation (424.510(f)). The exceptions in the text include providers that share office space with another provider, treat patients in the patients' homes, or perform telehealth from home.

McKnight's Home Care called the final provisions "not quite as bad as those proposed in July" but "sweeping and punitive." The AHA said most of the provisions apply to all enrolled provider types.

What's specific to hospices?

Three things stand out, per the rule's regulatory text:

1. Medical director and administrator limits. CMS may deny a hospice's enrollment if its medical director or administrator holds that role at multiple other hospices, or is located so far away that the person "cannot realistically perform" the required functions. It may also deny if the medical director lacks an active physician license in the state where they practice (424.530(a)(20)). CMS's text gives "a different state" as an example of distance.
2. Survey before reactivation. Hospices now join home health agencies in needing an initial State survey or accreditation before billing privileges can be reactivated after deactivation (424.540(b)(3)(i)). CMS estimates about $1.4 million a year for those surveys.
3. Ownership changes within 36 months. A hospice or home health agency that changes majority ownership within 36 months of initial enrollment, or of its last such change, generally must enroll as a new provider and pass a survey or accreditation. The rule adds denial and revocation grounds for failing to follow that process (424.530(a)(22), 424.535(a)(25)).

What's different for home health agencies?

Home health agencies were already subject to the 36-month rule and the survey-before-reactivation rule, so the new provisions mostly come from the all-provider changes: the new denial and revocation grounds, the signage requirement, the broader reapplication bar and the shorter post-revocation claims window. CMS also finalized a requirement that documentation providers must retain and furnish be "accurate, complete, and compliant with all CMS requirements" (424.516(f)(3)).

What did the 15-day claims window change?

This is easy to miss. Before, a revoked provider other than a home health agency had 60 calendar days after the revocation's effective date to submit claims for services furnished earlier. Under the final text, it has 15 calendar days from the date of the revocation letter (424.535(h)(1)(i)). A revoked home health agency's 15 days run from the letter date as well, for services before the later of the dates the rule lists. CMS rejected a request to count from when the letter is received, saying the letter date "adds far more certainty." It said the 15 days do not apply to claims resubmitted after a revocation is reversed on appeal.

What did CMS drop?

Three proposals did not survive comments, according to the rule and McKnight's:

• Expanding the Medicare-debt denial ground to managing employees, managing organizations and others with a business or financial relationship (424.530(a)(6)).
• Expanding the payment-suspension denial ground the same way (424.530(a)(7)).
• Letting CMS revoke a provider's other enrollments after a denial (424.535(i)).

On affiliations, CMS finalized its revised definition with two changes, including removing beneficiary relationships from one paragraph.

When does this take effect?

Update, Nov. 9: the rule published Monday at 91 FR 72022. Its DATES section now reads, as printed: "With the exception of the HH PPS and HH QRP provisions specified in sections II. and III. of this final rule and the regulatory changes at 42 CFR 484.245, these regulations are effective on January 4, 2026." The payment and quality-reporting provisions and 484.245 take effect Jan. 1, 2027. The printed "January 4, 2026" comes before publication. We're quoting it exactly and not substituting a date, and as of Monday morning we found no correction notice. The pre-publication copy had said 60 days after filing, which we had counted as Jan. 3, 2027. The rule's changes to the moratorium regulation are in a separate story.

What does CMS expect it to cost?

CMS's impact table estimates about $82 million a year flowing from providers and suppliers to the government because of the expanded retroactive revocation grounds. It projects $46.8 million over the first three years, or $15.6 million a year, for providers to comply with the signage requirement, and about $1.4 million a year for hospice reactivation surveys.

Where do reports differ from the rule?

• "Savings" versus "transfers." Hospice News reports the $82 million as "annual savings." The rule's table calls it a transfer from providers to the federal government.
• "Proposed" versus "finalized." The same Hospice News story uses "proposed" in places, though the rule is final.
• How broad the retroactivity is. The AHA says the changes "make all enrollment revocations retroactive." The regulatory text gives each ground its own effective date, and the paragraph for exceptions, (g)(2), reads "[To be added]" in the public inspection copy, and still does in the version published Nov. 9.

What to watch

Watch for any Federal Register correction of the printed effective date, any CMS or MAC guidance on how the new grounds will be applied, and any change to the enrollment forms. Hospice News quoted CMS Administrator Dr. Mehmet Oz saying the provisions give CMS "additional tools to protect Medicare beneficiaries and taxpayer dollars." Trade groups, including LeadingAge, have said the new grounds have "very few guardrails," as quoted by McKnight's. We have not seen the final text applied to a real case.

Not clinically reviewed. Informational only, not billing, legal or clinical advice. Check the linked primary source and your Medicare Administrative Contractor.

Sources

• Federal Register, CMS-1844-F, FR Doc. 2026-22750, 91 FR 72022, Nov. 9, 2026
• CY 2027 HH PPS final rule, public inspection PDF, FR Doc. 2026-22750 (CMS-1844-F)
• Federal Register public inspection listing, FR Doc. 2026-22750
• McKnight's Home Care, "Medicare providers beware new harsh enrollment provisions," Nov. 6, 2026
• AHA News, "CMS finalizes changes to provider enrollment provisions," Nov. 4, 2026
• Hospice News, "CMS Finalizes 2027 Home Health Rule With Sweeping Regulatory Changes," Nov. 4, 2026

Photo: Carol M. Highsmith, Library of Congress, via Wikimedia Commons, public domain (cropped). The lobby of the CMS headquarters building in Woodlawn, Maryland, December 2007. File photo; illustration only.

Drafted with AI assistance from primary sources. Written and edited by the Home Health Brief newsroom under Monsaur Othman's editorial standards. Read how we use AI, our editorial policy and our corrections policy.