LeadingAge and the National Alliance for Care at Home (the Alliance) submitted new letters urging the Centers for Medicare & Medicaid Services (CMS) to allow the moratorium on Medicare home health enrollment to expire — even after LeadingAge has supported the freeze.

These new letters also urge CMS to adopt more targeted enforcement measures to avoid implicating compliant providers.

“National data does not demonstrate that fraud, waste or abuse in home health or hospice is so pervasive and geographically uniform as to warrant an extension of the enrollment moratoria across all 50 states and territories,” Jennifer Sheets, CEO of the Alliance, wrote in the Sept. 4 letter. “Data consistently identifies fraud hotspots concentrated in specific metropolitan areas and states, not a nationwide epidemic of equivalent severity.”

The Alliance urged the CMS to allow the home health and hospice enrollment moratoria to expire on Nov. 13, six months after CMS enacted them.

The organization also listed several consequences of the moratoria. For instance, it stated that 38% of Medicare beneficiaries did not receive the home health services they were referred for after a hospital discharge in Q3 2025 — and beneficiaries in rural areas faced worse access to care.

“While the moratorium did not cause this access gap, it prevents those providers who are best positioned to help close these gaps from doing so,” the Alliance’s letter read.

Additional consequences include health systems delaying or abandoning home health partnerships because agencies cannot submit Medicare enrollment paperwork, creating unnecessary roadblocks for organizations.

Based in Alexandria, Virginia, the Alliance is an advocacy organization representing more than two million professionals in home health, home care, hospice and other healthcare fields.

LeadingAge also urged CMS to allow the moratoria to expire in a letter dated Sept. 9. The organization originally supported the moratorium and called it a tool to allow CMS time to develop a longer-term solution.

“We have not wavered in our position that targeted program integrity efforts to root out bad actors is necessary,” LeadingAge’s letter read. “However, it is becoming increasingly clear that legitimate providers are being caught in the crossfire of this war against fraud.”

LeadingAge is a Washington, DC-based association composed of 5,300 nonprofit providers and organizations offering services, including home-based care, for older adults.

Speaking out against final rule enrollment proposals

Legitimate providers may face severe enrollment consequences based on technical errors, conduct outside of their control or third-party associations rather than intentional impropriety, LeadingAge’s Aug. 31 letter argues. Beneficiaries lose access to care when legitimate providers are removed from Medicare.

“We fundamentally support CMS’ efforts to protect the Medicare Trust Funds and Medicare beneficiaries from fraud, waste and abuse,” LeadingAge’s letter reads. “As proposed, however, these provisions substantially expand CMS’s denial, revocation, reporting and related enforcement authorities while removing or failing to establish objective standards and procedural safeguards.”

LeadingAge and the 18 other organizations supporting the letter urged CMS to distinguish intentional misconduct from good-faith errors, as providers should not face the same consequences for clerical mistakes and documentation deficiencies as deliberate fraud.

CMS should also preserve due process, allowing providers to address inaccurate information, remedy technical deficiencies and dissociate from a problematic individual or entity before losing enrollment, the letter continued.

“We wish to be abundantly clear: our organizations do not oppose stronger fraud enforcement,” LeadingAge’s letter reads. “But CMS can target bad actors without creating an enrollment regime in which broad discretion, undefined standards, third-party conduct or technical compliance failures produce disproportionate consequences for legitimate providers.”

The letters build upon prior signed letters from LeadingAge and the Alliance urging CMS agency to crack down on fraud, waste and abuse without affecting legitimate providers.