From the Desk of the CEO: CMS Nationwide Moratorium on Home Health & Hospice Enrollment — Our Response

To our valued clients, I am writing personally because I know many of you are worried. On May 13, 2026, the
Centers for Medicare & Medicaid Services (CMS) announced a temporary nationwide moratorium on the
Medicare enrollment of new Home Health Agencies and Hospice providers. The moratorium was effective
immediately, with the Federal Register notice scheduled for publication on May 15, 2026. It is currently set to
last six months.

I want to acknowledge plainly that this announcement has created real anxiety across our industry — and
inside our own offices. That concern is understandable, and you deserve a thoughtful response, not
speculation.

WHAT WE KNOW RIGHT NOW

Based on the initial CMS announcement and the published moratorium Q&As, here is what is currently
understood. We are sharing this for general awareness only — formal guidance to each client will follow once
operational direction is received.

◆ The moratorium applies to initial Medicare enrollment applications for Home Health Agencies and
Hospices, and to non-exempt changes in majority ownership (CIMOs) under 42 CFR §424.550(b).
◆ Existing, already-enrolled providers are not affected in their day-to-day operations. They may continue
to bill, serve patients, submit changes of information, and meet revalidation requirements.
◆ The moratorium addresses Medicare. Whether and how it extends to Medicaid and CHIP is being left
to each individual state, and that landscape is still developing.

WHAT WE ARE DOING

I want every client to hear this directly from me: we are not standing still, and we are not guessing. Our team
is actively working on this situation on multiple fronts.

◆ Reviewing the Federal Register notice, line by line, so that our interpretation is grounded in the actual
rule — not headlines.
◆ Consulting with industry partners, national associations, and trusted legal and regulatory colleagues to
align on a consistent, defensible interpretation.
21st Century Health Care Consultants | Sarasota, Florida | www.HomeHealthcareConsultants.com
◆ Awaiting operational guidance from CMS and the Medicare Administrative Contractors (MACs), which
historically clarifies how applications, CHOWs, pending files, and edge-case scenarios will actually be
processed.
◆ Auditing every active client file — pending applications, ownership changes, accreditation timelines,
state licensure milestones — so that when guidance is released, we can move decisively on your behalf
rather than starting from scratch.
◆ Identifying the strongest available path forward for each client based on where their file sits today,
including options that may be unaffected by the moratorium.

A WORD ON THE TIMELINE

I want to be clear with you: at this moment, we do not have a firm timeline for when CMS and the MACs will
release the operational guidance we are waiting on. Historically, this kind of guidance arrives in stages —
sometimes within days, sometimes over several weeks. We will not speculate, and we will not give you an
answer we cannot stand behind. What we will do is keep you informed as soon as we have something concrete
to share.

OUR COMMITMENT TO YOU

You chose 21st Century Health Care Consultants because you wanted a partner who would keep you informed,
protect your interests, and stay in the fight when the rules change. That commitment has not wavered, and it
will not waver now. Every client currently in a project with our firm will be contacted directly as soon as we are
able to provide file-specific guidance.

We will get through this together — carefully, accurately, and with the same standard of documentation and
defensibility that has defined our work from the beginning. Thank you for your trust, your patience, and your
partnership.

With sincere appreciation,

Thomas Rose
Chief Executive Officer
21st Century Health Care Consultants