The CMS Moratorium Changes the Conversationby Jamie Daugherty, Executive Director Today, CMS announced a six-month nationwide moratorium on new Medicare enrollments for home health agencies and hospices, citing ongoing concerns around fraud, waste, and abuse. For providers across Oregon, this announcement immediately raises questions—not only about enrollment and growth, but about oversight, access, and the broader direction of home-based care policy. Fraud Prevention Matters Let’s start with what should be obvious: Fraud harms patients, undermines trust, and damages the integrity of the Medicare benefit. Bad actors in healthcare should absolutely be identified and removed from the system. Recent concerns around fraudulent activity in certain parts of the country—particularly involving hospice and home health enrollments—have received significant national attention. Legitimate providers have every reason to support strong program integrity efforts. But Broad Policy Has Broad Impact At the same time, nationwide actions create nationwide consequences. The new CMS moratorium applies broadly to new Medicare enrollments for home health and hospice providers across the country for six months. That includes states and communities where providers are already struggling with:
For many providers, the concern is not whether fraud should be addressed—it absolutely should be. The concern is whether broad national policy can effectively target fraud without unintentionally impacting access and sustainability in areas already facing capacity challenges. Oregon Has Already Taken a More Targeted Approach One important distinction here in Oregon is that the state has already recognized the need to balance oversight with access. With the passage of SB 1575, Oregon implemented its own moratorium process designed to address concerns around fraud and market saturation while also accounting for legitimate providers and the realities of rural access. That matters. Because healthcare access in Oregon is not uniform. Many communities—particularly rural and frontier areas—already face limited provider availability, workforce shortages, and long travel distances for care. A broad national moratorium risks treating all markets the same, even when the realities on the ground are very different. Oregon’s approach acknowledges something important: protecting program integrity and preserving access are not mutually exclusive goals. Legitimate providers serving communities in good faith should not be unintentionally caught in policies designed to address bad actors elsewhere. For providers across the state, the key question moving forward is whether federal actions will allow enough flexibility to recognize those regional differences and existing state-level safeguards. This Is Bigger Than Enrollment Even for agencies not directly affected by the moratorium, this announcement signals something larger: Federal scrutiny of home-based care is increasing. That means providers should expect continued focus on:
For agency leaders, this reinforces the importance of strong operational systems and a continued focus on compliance and quality. The Role of Advocacy Moments like this are exactly why advocacy matters. Providers need a voice in conversations that shape how policy is implemented and how operational realities are understood. OAHC will continue monitoring developments related to the CMS moratorium and broader federal actions affecting home health, hospice, and home care providers. Because protecting the integrity of care at home and protecting access to care at home are not competing priorities. Both matter. Moving Forward The coming months will likely bring additional discussion, clarification, and debate around this moratorium and what follows next. For providers, the challenge will be navigating increased scrutiny while continuing to deliver high-quality care in increasingly complex environments. And for policymakers, the challenge will be ensuring that efforts to prevent fraud do not unintentionally limit access for the patients and communities who depend on legitimate providers every day. Because the future of care at home depends on both accountability and access. OAHC will continue advocating for policies that protect program integrity while preserving access to high-quality home-based care across Oregon. |