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CMS Extends Home Health Agency Enrollment Moratorium for Six Months

The Centers for Medicare & Medicaid Services ("CMS") recently extended the temporary moratorium on the Medicare enrollment of new home health agencies ("HHAs"), subunits, and branch locations in Michigan.

Effective July 29, 2017, the moratorium was extended for an additional six months. The temporary moratorium also precludes the Medicare enrollment of new HHAs in Florida, Illinois, and Texas.

The HHA moratorium previously applied only to Wayne County and surrounding counties in Michigan, but it was extended to the entire state of Michigan as of July 29, 2016. CMS stated that the extension was necessary due to a high risk of fraud, waste, and abuse in the affected areas. CMS may continue to extend the moratorium in six-month increments.

The moratorium does not apply to any of the following changes: (1) changes in practice location; (2) changes in provider or supplier information, such as phone number or address; or (3) changes in ownership (unless the change in ownership triggers an initial enrollment under the 36-month rule). Limited waivers to the moratorium may be available on a case-by-case basis if an access to care issue exists.

Please contact Jennifer Van Regenmorter or Julie Hamlet if you have questions about how your organization may be impacted by the moratorium.

Categories: Medicare/Medicaid, Providers

 has particular expertise in health law and she represents providers with emphasis in the areas of physicians, hospice, home care and long term care, including one of the country’s largest long-term care organizations. She has a vast array of experience in teaming with providers in the areas of regulatory compliance and contracts. 

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Best Lawyers® 2020

Congratulations to the attorneys of the Health Care practice group at Foster Swift Collins & Smith, PC for their inclusion in the Best Lawyers in America 2020 edition. Firm-wide, 42 lawyers were listed. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation and as lawyers are not required or allowed to pay a fee to be listed; inclusion in Best Lawyers is considered a singular honor. Health Care practice group members listed in Best Lawyers are as follows:

To see the full list of Foster Swift attorneys listed in Best Lawyers 2020, click here.