Buying a Home Health Agency? Check It Before You Sign

As of October 26, 2026, Medicare is not enrolling new home health agencies. CMS's moratorium started on May 13, 2026. For anyone who planned to start an agency, buying one that is already enrolled is the other road in.

Before you sign, check the agency. Much of what you need is public. This article covers what to check, where to find it, and what only the seller can give you.

A note on labels. A rule is a federal regulation; I cite the paragraph and quote it from Cornell's Legal Information Institute. The moratorium notice is CMS's own notice in the Federal Register, quoted. A Logicly estimate is a figure we work out from Medicare's files; it is not a Medicare number. None of this is legal advice. Use a healthcare attorney for the deal itself.

The Short Answer

1. Check the 36-month rule first. A sale of a majority of the agency within 36 months of its initial Medicare enrollment, or of its last change in majority ownership, means the agency must enroll as a new one, unless an exception applies. As of October 26, 2026, the moratorium blocks new enrollments.
2. Check its quality. The free agency profile shows its two Care Compare star ratings and how its patients did against the state average.
3. Check who owns it. The same profile lists the companies that own 5% or more of it, as the agency reported them to Medicare.
4. Check its Medicare business. The paid county report shows where it ranks in its county, what Medicare paid it and where its patients live, from Medicare data for 2024.
5. Ask the seller for the rest. The state survey report, the cost reports, payer contracts and private-pay revenue are not on these pages.

What the Moratorium Means for a Buyer

As of October 26, 2026, Medicare is not enrolling new home health agencies. CMS's notice in the Federal Register (FR Doc. 2026-09717, 91 FR 27954) says: "This moratorium is effective May 13, 2026." It also says "no new HHAs or HHA branches or practice locations will be enrolled into Medicare unless the HHA's enrollment application was received by the applicable Medicare contractor prior to this notice's effective date."

On how long it lasts, the notice says "a temporary enrollment moratorium imposed by CMS remains in effect for 6 months. If CMS deems it necessary, the moratorium may be extended in 6-month increments." Six months from May 13, 2026 is November 13, 2026. That date is our arithmetic, not a date CMS published. As of October 26, 2026, CMS had published no extension.

Agencies already enrolled keep furnishing services, but they cannot add a branch or practice location while the moratorium lasts. In CMS's words, apart from "their ability to add branches to their enrollments", "the moratorium would not impact the roughly 11,500 currently enrolled HHAs, which could continue furnishing services (assuming they remain compliant with all Medicare requirements)."

The 36-month rule

This rule decides whether your purchase is a change of ownership or a new enrollment. 42 CFR 424.550(b)(1):

Unless an exception in paragraph (b)(2) of this section applies, if there is a change in majority ownership of a home health agency (HHA) or hospice by sale (including asset sales, stock transfers, mergers, and consolidations) within 36 months after the effective date of the HHA's or hospice's initial enrollment in Medicare or within 36 months after the HHA's or hospice's most recent change in majority ownership, the provider agreement and Medicare billing privileges do not convey to the new owner.

The new owner must instead "Enroll in the Medicare program as a new (initial) HHA or hospice" and "Obtain a State survey or an accreditation from an approved accreditation organization" (42 CFR 424.550(b)(1)(i) and (ii)).

The moratorium notice ties the two together. It says § 424.550(b) "requires an HHA undergoing a non-exempt CIMO within 36 months of its initial enrollment (or within 36 months of its most recent CIMO) to enroll in Medicare as a brand new HHA". CIMO is CMS's short form for a change in majority ownership. The notice goes on: "our moratorium would prohibit an HHA undergoing a non-exempt CIMO from reenrolling in Medicare because, again, it would constitute an initial enrollment".

So in a sale caught by the 36-month rule, the agency's Medicare enrollment ends and it cannot re-enroll while the moratorium lasts. The notice says "The HHA's current enrollment and provider agreement are terminated in these situations."

The four exceptions

42 CFR 424.550(b)(2) lists four cases where the 36-month rule does not apply:

• "The HHA or hospice submitted 2 consecutive years of full cost reports since initial enrollment or the last change in majority ownership, whichever is later." The same paragraph adds that "low utilization or no utilization cost reports do not qualify as full cost reports."
• "An HHA's or hospice's parent company is undergoing an internal corporate restructuring, such as a merger or consolidation."
• The owners change the agency's business structure, for example from a corporation to a partnership, "and the owners remain the same."
• "An individual owner of an HHA or hospice dies."

The first is the one a buyer can check on paper. Ask the seller for the agency's last two full cost reports and the dates they cover.

What the moratorium leaves open

The notice also lists what the moratorium does not cover. Citing § 424.570(a)(1)(iii), it says the moratorium does not apply to "Changes in ownership (except changes in ownership of HHAs, hospices, and suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) that would require an initial enrollment)." (FR Doc. 2026-09717, section c.) So a sale outside the 36-month rule, or one that fits an exception, is a change of ownership the moratorium does not cover. Deals differ, so have a healthcare attorney confirm it for yours.

Every change of ownership still goes through Medicare. 42 CFR 424.550(b) says "the current owner and the prospective new owner must complete and submit enrollment applications before completion of the change of ownership." If the new owner does not file within 30 days of the change, "CMS may deactivate the Medicare billing number."

Your state may have its own rules on changes of ownership. Ask the state agency that licenses home health agencies before you sign.

Where to see the dates

The free agency profile shows the year Care Compare lists as the agency's certification date, and the year each owning company went on file with Medicare. The paid report shows the month the current owners were put on Medicare's records, and it says that date is "when the owners were put on file, not necessarily when the agency was bought."

These dates are a starting point. The 36 months run from the effective date of the agency's initial Medicare enrollment, or from its most recent change in majority ownership. Ask the seller for the enrollment records that show those dates.

What the Free Profile Shows

Each agency profile on this site is free. It shows:

• Two star ratings from Care Compare: quality of patient care, and the patient survey.
• How patients did: each quality measure against the average agency in the state, plus preventable hospital stays, patients sent home to the community and Medicare spending per episode against the nation.
• What patients said: the patient survey results, against the state and the nation.
• Medicare payment: the agency's result in Medicare's value-based purchasing program, with its total performance score and its payment adjustment.
• Who owns it: the companies that own 5% or more of it, directly or through other companies, as the agency reported them to Medicare. People and family trusts are counted, not named.
• About the agency: its services, its ownership type (for-profit, non-profit or government), the year it was certified, its address, a link to its county's home health page and the ZIP codes it serves.

What the Paid Report Adds

The report is on one agency, drawn against every agency in a county you choose (the county report, $129) or every agency in its state (the state report, $199). A third plan, $79, puts it next to one other agency you pick. All are one-time purchases and use Medicare data for 2024. The county report shows:

• Where it ranks among the agencies in the county.
• What Medicare paid it, with its Medicare patients and payment by year.
• A Logicly estimate of its Medicare margin, worked out from its 2024 cost report. This is our figure, not a Medicare number.
• What it pays clinicians per visit, for nurses, therapists and aides. This is also a Logicly estimate.
• Where its patients live, by ZIP code.
• Who owns it, from the same CMS All Owners file the free profile uses, with the owner chain up to the parent company and the month the current owners went on file.

The state report adds the agencies that opened and closed in the state since 2020, from CMS's Provider of Services file.

What the Data Cannot Tell You

The profile and the report are built from public Medicare files. These are not in them:

• Private-pay, Medicaid and Medicare Advantage revenue. The report's patient counts and payments cover traditional Medicare only.
• Medicaid rates and payer contracts.
• Leases, staff contracts and referral agreements.
• State survey findings. The patient survey on the profile is what patients said. The findings from the state's inspection of the agency are not on these pages.
• Anything after 2024 in the Medicare payment figures.

Ask the seller for the report from the agency's most recent state survey and any plan of correction, its Medicare cost reports, its payer contracts, its revenue by payer, and the enrollment records that show when it first enrolled and when its ownership last changed.

How to Run the Check

1. Find the agency with the free agency finder, or browse agencies by state and city. Open its profile.
2. Read the profile: the star ratings, how patients did, who owns it, the year it was certified.
3. On the profile, choose "Thinking of buying this agency? Check it first". That opens the order for the county report on that agency, $129 one time. Pediatric agencies and agencies without published Medicare figures have no report.
4. Starting from the agency reports page instead? Pick a plan. With Your county or Your state, enter the agency you are looking at as "your agency". With Your agency, the $79 plan, enter it under "Compare it with". The report is on that agency.

Frequently Asked Questions

Can I buy a home health agency during the 2026 moratorium?

In most cases, yes. As of October 26, 2026, CMS's moratorium stops new home health agencies from enrolling in Medicare. The notice says, citing § 424.570(a)(1)(iii), that the moratorium does not apply to "Changes in ownership (except changes in ownership of HHAs, hospices, and suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) that would require an initial enrollment)" (FR Doc. 2026-09717). The catch is the 36-month rule in 42 CFR 424.550(b). If a majority of the agency changes hands within 36 months after its initial enrollment, or after its most recent change in majority ownership, and no exception applies, the agency's enrollment ends and it cannot re-enroll while the moratorium lasts. Deals differ, so have a healthcare attorney confirm it for your deal. As of October 26, 2026, CMS had published no extension of the moratorium.

Does buying an agency count as a new Medicare enrollment?

Only in some sales. Under 42 CFR 424.550(b)(1), if a majority of the agency changes hands by sale within 36 months after the effective date of its initial Medicare enrollment, or within 36 months after its most recent change in majority ownership, the provider agreement and billing privileges do not pass to the buyer. The buyer must enroll the agency as a new one and get a state survey or accreditation. The rule has four exceptions. The one a buyer can check on paper is two consecutive years of full cost reports since the initial enrollment or the last change in majority ownership. CMS's moratorium notice says that in these sales "The HHA's current enrollment and provider agreement are terminated", and that re-enrolling "would constitute an initial enrollment", so the agency cannot re-enroll while the moratorium lasts.

How do I check a home health agency before buying it?

Find the agency with the free agency finder and open its profile. The profile shows its Care Compare star ratings, how its patients did against the state average, the companies that own 5% or more of it, the year it was certified and the ZIP codes it serves. For its Medicare business, order the county report on it: where it ranks in its county, what Medicare paid it, a Logicly estimate of its Medicare margin and where its patients live, from Medicare data for 2024. Then ask the seller for what is not public: the latest state survey report, its cost reports, its payer contracts and its private-pay revenue.

What does the agency report cost?

$79 for the report on the agency next to one other agency you pick, $129 for the county report, or $199 for the state report. Each is one time and uses Medicare data for 2024.

Sources

The moratorium (Federal Register):

• FR Doc. 2026-09717, Announcement of Nationwide Temporary Moratoria on Enrollment of Home Health Agencies, 91 FR 27954, published May 15, 2026. Quoted: the effective date, the scope, the 6-month length; section c, the cases the moratorium does not cover (changes in ownership, citing § 424.570(a)(1)(iii)); the currently enrolled agencies and their branches; and section D on § 424.550(b), including that the enrollment and provider agreement are terminated.
• Federal Register, documents from the Centers for Medicare & Medicaid Services. Searched October 26, 2026 for any extension of the home health moratorium published since May 16, 2026; none found.

Federal rule (Cornell LII):

• 42 CFR § 424.550, Prohibitions on the sale or transfer of billing privileges, read October 26, 2026. Relied on: paragraph (b), the opening sentence on changes of ownership and the 30-day sentence on deactivation; paragraph (b)(1), the 36-month rule and its requirements (i) and (ii); and paragraph (b)(2)(i) to (iv), the four exceptions.

CMS data behind the profile and the report:

• CMS Home Health Agency All Owners: who owns each agency, on the profile and in the report.
• CMS Care Compare, Home Health Care Agencies: the star ratings, quality measures, services, ownership type and certification date on the profile.
• CMS Medicare Post-Acute Care Utilization: Medicare patients and payment in the report, 2024.
• CMS Home Health Agency Cost Report: the basis of the Logicly margin estimate, fiscal year 2024.
• CMS Provider of Services File: agencies opening and closing, in the state report.