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07/14/2026

CMS' Proposed Enrollment Changes Could Affect Providers Across the Care Continuum

Just one week after CMS released the CY 2027 Home Health Proposed Rule, providers and national organizations are raising concerns about several proposed Medicare enrollment and program integrity provisions that would significantly expand CMS' authority to deny or revoke Medicare enrollment.

Among the proposals drawing the most attention are among the most significant proposals are expanded grounds for Medicare enrollment revocation, retroactive effective dates for certain revocations, and reenrollment bars of up to 10 years in some circumstances. While provider organizations continue to support efforts to combat fraud and abuse, many are urging CMS to ensure enforcement remains targeted and evidence based so compliant providers are not unintentionally caught up in expanded oversight activities.

At the same time, CMS is signaling that broader regulatory changes may be ahead. A separate proposed rule currently under review by the Office of Management and Budget would modernize the Medicare Conditions of Participation and other provider requirements with the stated goal of reducing administrative burden and increasing operational flexibility. Details have not yet been released, but LeadingAge will continue monitoring the proposal as more information becomes available.

Why it matters

The proposed enrollment changes would affect far more than home health agencies. If finalized, they could impact Medicare enrollment, ownership changes, compliance, and billing practices across hospice and other provider types. While none of these proposals are final, they offer an early look at CMS' continued emphasis on program integrity alongside broader efforts to streamline regulations.

What to do

  • Review the proposed Medicare enrollment and revocation provisions if you have not already.
  • Evaluate your organization's enrollment, ownership, and compliance processes for potential areas of risk.
  • Watch for additional analysis from LeadingAge and LeadingAge Ohio as the proposed rule moves through the comment process.
  • Stay engaged as CMS releases additional details on its broader deregulatory initiative.

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