Last updated: November 2026
Medicare hospice certification means a hospice meets the Conditions of Participation in 42 CFR Part 418 and is enrolled in Medicare. Since May 13, 2026, a nationwide CMS moratorium has barred enrollment of new hospices that had not already applied, and accreditation does not give a new hospice deemed status while it lasts. Integral Healthcare Solutions (IHS) is a consulting firm that drafts the Part 418 policy and procedure set, the plan-of-care and quality documents, the personnel file checklist and the mock-survey tracers, so a hospice is ready when enrollment reopens.
What is Medicare hospice certification, and is there a moratorium?
Part 418 sets the hospice Conditions of Participation. Its first section states: "This part implements section 1861(dd) of the Social Security Act (the Act)" (42 CFR 418.1). We read the cited eCFR sections on November 6, 2026 (GPO text built November 4, 2026).
A moratorium is in effect according to the CMS page we opened. The Federal Register notice CMS-6102-N, published May 15, 2026, "announces the imposition of a 6-month nationwide moratorium on the Medicare enrollment of hospices," effective May 13, 2026 (Federal Register, 2026-09718). Its scope sentence reads: "Beginning on the effective date of this notice, no new hospices or hospice practice locations will be enrolled in Medicare unless the hospice's enrollment application was received by the applicable Medicare contractor prior to this notice's effective date." The CMS provider enrollment moratoria page, last modified August 27, 2026, still lists the moratorium as active (CMS, Provider Enrollment Moratoria).
The regulation says a moratorium "may be imposed for a period of 6 months and, if deemed necessary by CMS, may be extended in 6-month increments," and that CMS will publish a Federal Register document when it extends one (42 CFR 424.570, paragraph (b)). IHS counts six months from May 13, 2026 as reaching about November 13, 2026; that date is our arithmetic, not a CMS statement. We found no hospice extension or lifting notice in the Federal Register issues from October 1 through November 6, 2026. Status after November 13 is unverified, so check the CMS page.
What does the moratorium do to a new hospice application?
CMS memo QSO-26-11, dated May 20, 2026, states: "Initial enrollment applications submitted during the moratoria will be denied and the application will need to be resubmitted once the moratoria are lifted." "Prospective Hospice or HHA Medicare enrollment applications that were received by the applicable Medicare contractors prior to May 13, 2026, will continue to be processed." The memo also says "CMS regulations do not permit exceptions to a moratorium for individual providers or suppliers" (CMS, QSO-26-11).
Can accreditation substitute for the state survey during the moratorium?
Not for deemed status. QSO-26-11 states: "During the moratorium, a prospective Hospice or HHA's accreditation by a CMS approved Accrediting Organization (AO) program will not serve as the basis for Medicare participation through deemed status." A new provider agreement will not be approved in that case. Our ACHC hospice page covers one accrediting program; this page covers Part 418.
What does Part 418 test?
Four conditions show its shape (42 CFR Part 418).
- Patient rights, 418.52: "The patient has the right to be informed of his or her rights, and the hospice must protect and promote the exercise of these rights." The hospice gives written and verbal notice during the initial assessment visit and obtains a signature confirming receipt.
- Care planning, 418.56: the hospice designates an interdisciplinary group that, "in consultation with the patient's attending physician, must prepare a written plan of care for each patient." The group must review, revise and document the plan "as frequently as the patient's condition requires, but no less frequently than every 15 calendar days."
- Core services, 418.64: "A hospice must routinely provide substantially all core services directly by hospice employees." It allows contracted physician services and, "if necessary," contracted staff to supplement employees "under extraordinary or other non-routine circumstances."
- Quality, 418.58: it must "develop, implement, and maintain an effective, ongoing, hospice-wide data-driven quality assessment and performance improvement program."
Who needs it and what triggers it
- A new or expanding hospice planning licensure, enrollment and a survey. Under the moratorium, the work now is preparation. A newly enrolling hospice is screened at the high categorical risk level, which requires fingerprints from every individual with a 5 percent or greater direct or indirect ownership interest (42 CFR 424.518).
- A hospice acquirer. Unless an exception in paragraph (b)(2) applies, a change in majority ownership of a hospice by sale (including asset sales, stock transfers, mergers and consolidations) within 36 months after the effective date of initial enrollment in Medicare or within 36 months after its most recent change in majority ownership means the provider agreement and Medicare billing privileges do not convey to the new owner; the buyer must enroll as a new hospice and obtain a State survey or an accreditation from an approved accreditation organization (42 CFR 424.550, paragraph (b)(1)). Paragraph (b)(2) lists four exceptions, including an internal corporate restructuring by the parent company and the death of an individual owner; the cost-report exception has its own conditions, so read the paragraph. The CMS moratoria page says the moratorium "includes non-exempt changes in majority ownership." CMS's moratorium Q&A, last revised July 9, 2026, says the moratorium prohibits adding a new practice location to an existing enrollment (CMS, HHA and Hospice Moratorium FAQs).
- A hospice with an application at its Medicare contractor since before May 13, 2026.
State licensure steps vary by state, so the state licensing agency is the source for them.
How IHS helps
IHS has three practice lines: accreditation consulting, compliance services and program development. Hospice readiness sits in compliance services, led by Thomas G. Goddard, JD, PhD.
- A readiness assessment against Part 418, listing what exists and what a surveyor would ask for.
- A policy and procedure set for clinical leaders to approve.
- Plan-of-care and QAPI documents, and a personnel file checklist.
- Mock-survey tracers that follow a patient from admission to the record.
- A dated moratorium watch note.
What you supply: the owner, the medical director and clinical leaders, signatures and filings, state licensure materials, and counsel on the moratorium and any transaction.
The real limit: IHS cannot create an exception to the moratorium, and CMS says none exist for individual providers. IHS does not file with CMS, a state agency or an accrediting organization; your organization files.
What to have ready
Each item except the correction log ties to Part 418 or the CMS documents above.
- A patient rights notice and signature process that meets 418.52.
- An interdisciplinary group procedure, a plan-of-care template with the six contents in 418.56(c) and a 15-day review log.
- A staffing plan showing core services provided directly by hospice employees, with any contract arrangements documented (418.64).
- A bereavement program and plan of care; 418.64(d)(1) requires services available up to 1 year following the death of the patient.
- A QAPI plan that is data-driven and hospice-wide, with performance improvement projects documented, as 418.58 requires.
- Ownership records for every 5 percent owner, for the 424.518 fingerprint requirement.
- If buying, the initial enrollment effective date, the date of the most recent change in majority ownership and the sale date, for counsel to test the 36-month rule.
- Dated copies of the CMS moratoria page, notice CMS-6102-N and QSO-26-11.
- Credential records for the interdisciplinary group roles in 418.56(a)(1) and the qualified social worker in 418.64(c).
- A mock-survey correction log, which is a working record rather than a Part 418 requirement.
To see where your file stands, start with the introductory call.
How it compares
The comparison is the survey route. A State survey and an accreditation from an approved accreditation organization are the two routes 424.550(b)(1) names for a buyer that must enroll as a new hospice, and during the moratorium QSO-26-11 says accreditation will not serve as the basis for deemed status. The choice after the moratorium turns on your state, timeline and counsel's advice. See also home health and hospice accreditation consulting and, for a purchase, healthcare regulatory due diligence.
What it costs
Three costs apply. First, the government: a prospective institutional provider submitting an initial application must submit the applicable application fee, a request for a hardship exception, or both, and the fee is adjusted yearly by CMS (42 CFR 424.514). The fee is nonrefundable except in listed cases, including an application denied as a result of a temporary moratorium. We did not open a current dollar amount, so verify current fees with CMS and the Medicare contractor. Second, consulting: IHS scopes each engagement after a free introductory call. Scope turns on the number of sites, the services you plan, and the gaps between your documents and Part 418. Third, your own time: clinical leaders approve every clinical policy.
What this is not
- It is not legal advice. IHS is a consulting firm, not a law firm; moratorium and transaction questions belong with counsel.
- It is not a way around the moratorium. CMS regulations do not permit individual exceptions.
- It is not a guarantee of a survey or enrollment result. CMS and the survey agency decide.
Frequently asked questions
Is there a moratorium on new hospice enrollment right now?
CMS's moratoria page, last modified August 27, 2026, still lists a temporary nationwide moratorium on home health agencies and hospices that CMS implemented on May 13, 2026 (CMS). IHS counts its first six-month period as ending about November 13, 2026. We found no extension or lifting notice, so check the CMS page.
What happens to an application filed before the moratorium?
CMS memo QSO-26-11 says hospice and home health applications that the Medicare contractors received before May 13, 2026 "will continue to be processed" (CMS, QSO-26-11).
Can accreditation substitute for a state survey during the moratorium?
No, not for deemed status. QSO-26-11 says that during the moratorium, a prospective hospice's accreditation by a CMS approved accrediting organization "will not serve as the basis for Medicare participation through deemed status" (CMS, QSO-26-11).
What are the hospice Conditions of Participation?
They are in 42 CFR Part 418, which "implements section 1861(dd) of the Social Security Act (the Act)" (42 CFR 418.1). IHS maps your policies and records to Part 418.
What must a hospice plan of care contain?
Section 418.56(c) requires all services necessary for the palliation and management of the terminal illness and related conditions, and lists six items, from interventions to manage pain and symptoms to documentation of the patient's or representative's understanding and agreement (42 CFR 418.56). Your clinical leaders approve the template IHS drafts.
Which services must a hospice provide directly?
Section 418.64 states "A hospice must routinely provide substantially all core services directly by hospice employees" (42 CFR 418.64). The section allows contracted physician services and limited supplemental staffing. IHS builds the staffing documentation, and your leaders decide staffing.
What does QAPI require?
Section 418.58 requires an effective, ongoing, hospice-wide data-driven quality assessment and performance improvement program (42 CFR 418.58). IHS drafts the plan, and your clinical leaders choose the measures.
Does buying a hospice keep the Medicare agreement?
Unless a (b)(2) exception applies, a sale that changes majority ownership within 36 months after initial enrollment or within 36 months after the most recent change in majority ownership means the provider agreement and billing privileges do not convey, and the buyer must enroll as a new hospice and obtain a State survey or an accreditation (42 CFR 424.550). CMS says the moratorium includes non-exempt changes in majority ownership. Counsel decides how this applies to a deal.
What does IHS draft and what do clinical leaders approve?
IHS drafts the policy and procedure set, plan-of-care and QAPI documents, personnel file checklist and mock-survey tracers. Clinical leaders approve all clinical content, and your organization files with CMS and the state.