Key Takeaways CMS imposed nationwide six-month moratoria effective May 13, 2026, barring new Medicare enrollments for hospice and home health agencies as part of a broader program integrity initiative. The restrictions extend beyond new providers to certain ownership changes, branch additions and other expansion activity requiring initial enrollment applications. The moratoria create substantial operational and transactional risk for hospice and home health providers because routine business changes may now trigger prohibited enrollment activity. CMS also signaled heightened scrutiny of ownership structures, relocations and operational growth tied to alleged fraud and abuse concerns. Providers should carefully evaluate pending transactions, expansion plans and enrollment updates to determine whether they could trigger new Medicare enrollment activity during the moratoria period. Organizations also should monitor evolving state

Key Takeaways HRSA has extended the deadline for comments on its proposed 340B rebate model pilot program to April 20, 2026. Covered entities have a limited window to submit detailed feedback on how the model would affect operations and patient care. The proposed rebate model and new manufacturer data submission policies increase administrative burden and create risk of pricing denials and cash flow disruption. These changes could significantly expand compliance obligations and force providers into frequent disputes to recover 340B savings. Covered entities should submit detailed RFI comments and actively monitor 340B pricing access and denials. Providers should also begin tracking data, documenting losses and preparing for potential ADR filings and manufacturer engagement. The 340B program is experiencing rapid changes that could have a