Medicare enrollment for a home health agency (HHA) or hospice requires more than completing an application. Organizations must meet Medicare, state, financial, ownership, screening, and certification requirements before they can receive Medicare billing privileges.
Home health agencies and hospices enroll as institutional providers. The process generally involves obtaining an organizational NPI, completing CMS-855A, submitting enrollment information through PECOS, working with the Medicare Administrative Contractor (MAC), and completing applicable state and Medicare requirements.
There is also an important 2026 development. CMS implemented a temporary nationwide enrollment moratorium for new home health agencies and hospices on May 13, 2026. The moratorium initially lasts six months and may be extended. Organizations should verify the latest CMS guidance before submitting a new enrollment application.
2026 CMS Moratorium: What New HHAs and Hospices Need to Know
The first step in planning a new Medicare enrollment is checking whether the organization can currently submit an initial application. CMS’s current guidance states that the nationwide moratorium applies to new Home Health Agencies and Hospices. It also addresses certain changes involving majority ownership.
This does not mean organizations should stop preparing. A business planning to enroll can use the waiting period to organize its documentation, verify state requirements, prepare financial records, and ensure its organizational information is accurate.
What Should New Agencies Do During the Moratorium?
Organizations preparing for future Medicare enrollment should:
- Verify the latest CMS moratorium status.
- Complete applicable state licensing and certification steps.
- Obtain or verify the organization’s NPI.
- Organize ownership and controlling-interest information.
- Prepare required financial documentation.
- Review CMS-855A requirements.
- Set up a system for tracking enrollment requirements.
CMS can change or extend the moratorium, so checking the current CMS guidance should remain part of the enrollment process.
CMS-855A and PECOS: What’s the Difference?
CMS-855A is the Medicare enrollment application used by institutional providers, including home health agencies and hospices.
PECOS is CMS’s online Medicare enrollment system. Institutional providers can use PECOS to submit enrollment information, upload documents, electronically sign applications, and maintain enrollment records.
| Item | Purpose |
| CMS-855A | Institutional provider Medicare enrollment application |
| PECOS | Online Medicare enrollment system |
| NPI | Identifies the organization |
| MAC | Processes the Medicare enrollment application |
| State Agency | Handles applicable state review and certification |
CMS generally recommends electronic enrollment through PECOS, although paper CMS-855A remains available in applicable situations.
What Does a Home Health Agency Need Before Medicare Enrollment?
Preparation is one of the most important parts of the enrollment process. An HHA should make sure its basic organizational information is correct before completing CMS-855A or entering PECOS.
Verify the Legal Business Information
The legal business name, tax identification information, ownership details, and organizational structure should match the organization’s official records. Even small inconsistencies can create questions during enrollment review.
Obtain the Organizational NPI
A home health agency generally needs a Type 2 NPI, which identifies the organization rather than an individual provider. The NPI information should be consistent with the organization’s legal and enrollment information.
Confirm Ownership and Managing Personnel
CMS-855A requires information about applicable owners, authorized officials, and managing employees. Prepare this information before starting the application so that names, addresses, ownership percentages, and other required details can be entered accurately.
Review State Requirements
Medicare enrollment does not replace state licensing or certification requirements. The agency should determine what its state requires before submitting the Medicare enrollment application. State requirements can vary depending on the provider type and location.
HHA Capitalization Requirements
One of the most important HHA-specific requirements is the initial reserve operating funds requirement.
CMS-855A requires an HHA initially enrolling in Medicare, Medicaid, or both to provide documentation showing sufficient initial reserve operating funds to operate during the enrollment process and for three months after billing privileges are conveyed.
The MAC determines the required amount by comparing the HHA with at least three comparable new HHAs. Factors may include:
- Geographic location
- Number of visits
- Type of HHA
- Business structure
CMS-855A also contains requirements concerning documentation of available funds and non-borrowed funds. Because financial documentation can become a major part of the review, HHAs should prepare it before submitting the enrollment application.
How the Medicare Enrollment Process Works: Step-by-step Guide
Once the organization is ready, the enrollment process generally follows this sequence:
Organization setup → NPI → CMS-855A/PECOS → Supporting documents → MAC review → State review → Screening/site verification → Certification → Medicare approval
Step 1. Verify the Organization: Confirm the legal name, tax information, ownership, NPI, location, and authorized officials.
Step 2. Prepare CMS-855A: Collect the information required for the institutional provider application and supporting documentation.
Step 3. Submit Through PECOS: Enter the enrollment information, upload applicable documents, electronically sign, and submit the application when enrollment is permitted.
Step 4. Respond to Review Requests: The MAC or state agency may request additional information or documentation. Track every request and respond promptly.
Step 5. Complete Applicable Screening: Depending on the provider and risk category, Medicare enrollment may involve site verification and other screening requirements.
Step 6. Confirm Approval: After approval, verify the Medicare enrollment record and billing privileges before beginning Medicare billing.
Site Visits and Medicare Screening
Institutional providers should be prepared for applicable site verification. CMS states that a MAC may order a site visit before making a final enrollment decision. CMS also announced enhanced screening measures for HHAs and hospices in connection with the 2026 enrollment moratoria.
For HHAs, CMS specifically referenced site verification and fingerprinting-based background checks for high-risk HHAs.The organization’s reported location should therefore be accurate and reflect its actual operations. Review the:
- Physical address
- Business information
- Contact details
- Signage and accessibility
- Operational records
- Responsible personnel
The exact requirements depend on the applicable CMS and state rules.
Hospice Medicare Enrollment
Hospices also enroll as institutional providers and use CMS-855A and PECOS for Medicare enrollment. However, hospice enrollment has requirements that differ from those of home health agencies.
Hospice Organization Requirements
A hospice should prepare its:
- Legal entity information
- Organizational NPI
- Ownership information
- Authorized official information
- Managing employee information
- Physical location information
- State licensing and certification documentation
- Medicare enrollment documentation
The organization should also review applicable Medicare screening and certification requirements.
Hospice Certifying Physician Requirement
One important hospice requirement involves physicians who certify a patient’s need for hospice services. CMS requires applicable certifying physicians to be enrolled in Medicare or opted out of Medicare. This requirement became effective June 3, 2024.
Hospices should verify the physician’s Medicare enrollment or opt-out status instead of assuming that an existing relationship with the hospice satisfies the requirement.
HHA vs. Hospice Medicare Enrollment
Although both organizations use the institutional provider enrollment process, some requirements differ.
| Area | HHA | Hospice |
| CMS-855A | Yes | Yes |
| PECOS | Yes | Yes |
| Organizational NPI | Yes | Yes |
| HHA capitalization requirement | Yes | No |
| Site verification | May apply | May apply |
| Enhanced screening | May apply | May apply |
| Certifying physician enrollment requirement | No | Yes |
| 2026 new enrollment moratorium | Yes | Yes |
The shared CMS-855A process does not mean the two provider types have identical enrollment requirements.
Documents to Prepare for Medicare Enrollment
Keeping all documents in one organized enrollment file can make the process easier.
Organizational Documents
Prepare applicable:
- Legal entity documents
- Tax information
- Organizational NPI information
- Ownership records
- Authorized official information
- Managing employee information
Location and Licensing Documents
Keep copies of:
- State licenses
- Certifications
- Physical location documentation
- Applicable state agency records
- Other required facility documentation
Financial Documents for HHAs
HHAs should pay particular attention to their financial documentation. Depending on the circumstances, this may include bank statements, financial attestations, and documentation supporting the required reserve operating funds.
Enrollment Records
Maintain copies of:
- CMS-855A
- PECOS submission
- Supporting documents
- MAC correspondence
- State agency correspondence
- Approval notices
A centralized file helps the enrollment team respond quickly when Medicare or the state agency requests additional information..
6 Common Home Health Medicare Enrollment Mistakes to be avoided
Applying Without Checking the Moratorium: In 2026, organizations should confirm the current CMS moratorium status before submitting an initial application.
Inconsistent Organizational Information: The legal name, tax information, NPI, ownership information, and enrollment application should match.
Underestimating HHA Capitalization Requirements: Financial documentation should be prepared before submission rather than after the MAC requests it.
Ignoring Site Verification: The reported location should accurately represent the organization’s physical operations.
Delaying Responses to MAC Requests: Unanswered requests can slow the enrollment process. Assign responsibility for monitoring and responding to every request.
Forgetting Post-Enrollment Changes: Medicare enrollment requires ongoing maintenance. Changes to ownership, locations, and other enrollment information may need to be reported within CMS requirements.
Medicare Enrollment Tracking Template
A simple tracker can keep the enrollment team organized.
| Enrollment Item | Status |
| Legal entity | Complete |
| Ownership | Complete |
| Organizational NPI | Complete |
| CMS-855A | In Progress |
| PECOS | In Progress |
| Capitalization documents | Complete |
| State documentation | Pending |
| MAC review | Pending |
| Site verification | Pending |
| Screening | Pending |
| Final approval | Pending |
| Billing setup | Pending |
Update the tracker whenever the application status changes or the MAC or state agency requests additional information.
What Happens After Medicare Approval?
Medicare approval is not the end of the enrollment process. An HHA or hospice must continue maintaining accurate enrollment information.
Monitor Organizational Changes
Track changes involving:
- Ownership
- Practice or service locations
- Authorized officials
- Managing employees
- Legal business information
- Other information reported to Medicare
CMS requires providers to report certain changes within specific timeframes. Ownership changes, adverse legal actions, and practice location changes generally fall under a 30-day reporting requirement, while many other changes have a 90-day timeframe.
Keep Enrollment Records Updated
Maintain copies of Medicare approval notices, enrollment submissions, correspondence, and supporting documentation. A centralized record makes future updates and revalidation easier.
Monitor Revalidation
Institutional providers must also monitor their Medicare revalidation requirements. Do not wait until a revalidation deadline is approaching to begin collecting documentation.
Home Health and Hospice Medicare Enrollment Checklist
Before Enrollment
- Confirm current CMS requirements
- Check the active moratorium status
- Verify the legal entity
- Confirm ownership
- Obtain or verify the organizational NPI
- Review state requirements
- Organize supporting documents
During Enrollment
- Prepare CMS-855A
- Complete PECOS
- Submit supporting documents
- Prepare HHA capitalization documentation when applicable
- Monitor MAC requests
- Track state review
- Prepare for applicable screening and site verification
After Approval
- Confirm Medicare billing privileges
- Verify enrollment information
- Update billing systems
- Monitor reporting deadlines
- Maintain supporting documentation
- Track revalidation requirements
Final Takeaway
Home health agency Medicare enrollment involves more than CMS-855A and PECOS. Organizations must coordinate their legal information, NPI, ownership records, financial documentation, state requirements, Medicare screening, and MAC review.
For HHAs, the reserve operating funds requirement deserves special attention. Hospices also need to monitor the Medicare enrollment status of applicable certifying physicians. In 2026, new HHAs and hospices must also check the CMS nationwide enrollment moratorium before submitting an initial Medicare application.
Preparing the organization and documentation in advance gives the enrollment team a stronger foundation and helps reduce avoidable delays when Medicare enrollment is available.
FAQs
Can a new home health agency enroll in Medicare in 2026?
As of the latest CMS guidance available in August 2026, a nationwide moratorium is active for new Medicare enrollment of home health agencies and hospices. Organizations should check CMS for the current status before submitting an initial application.
What form does a home health agency use for Medicare enrollment?
Home health agencies are institutional providers and use CMS-855A for Medicare enrollment. The application can generally be submitted electronically through PECOS.
What is PECOS?
PECOS is CMS’s online Medicare enrollment system. It allows providers to submit and manage Medicare enrollment information electronically.
Do HHAs have capitalization requirements?
Yes. HHAs initially enrolling in Medicare, Medicaid, or both must provide documentation supporting sufficient initial reserve operating funds under the applicable CMS-855A requirements.
Does a hospice use CMS-855A?
Yes. Hospice organizations are institutional providers and use CMS-855A for Medicare enrollment.
Do hospice certifying physicians need Medicare enrollment?
Yes. Applicable physicians who certify the need for hospice services must be enrolled in Medicare or opted out of Medicare.
Can Medicare conduct a site visit?
Yes. CMS states that a MAC may order a site visit before making a final enrollment decision.
