How to Get a Medicare-Certified Home Health Agency

Becoming a Medicare-certified home health agency means getting a state license, enrolling with Medicare on CMS Form 855A, building a small patient census, and passing an initial certification survey — either by your state survey agency or by a CMS-approved accrediting organization. One large caveat sits on top of all of that right now: on May 13, 2026, CMS imposed a nationwide temporary moratorium on new home health agency enrollments, so any Medicare enrollment application not already on file with a Medicare contractor before that date will be denied.¹ You can still complete state licensing and operational setup, but the Medicare piece is paused.

The Enrollment Moratorium Comes First

The moratorium covers all 50 states, U.S. territories, and the District of Columbia, and it applies to new agencies as well as new branches and practice locations.¹ It runs for six months and can be extended in six-month increments or lifted earlier. Applications received before May 13, 2026, keep processing. Anything filed on or after that date is denied and has to be resubmitted once the moratorium ends.²

There are no individual exceptions. The Federal Register notice states there is no judicial review of the decision to impose the moratorium, though a denied provider can administratively appeal on the narrow question of whether the moratorium actually applies to them.¹² The moratorium also blocks re-enrollments triggered by the 36-month change-in-majority-ownership rule at 42 CFR §424.550, because that re-enrollment counts as a new application.³ Routine updates to existing provider information — changes of address or phone number, for example — are not affected.

When the pause lifts, agencies that were blocked will be placed in the “high” screening category for applications submitted within the six months after.¹

Step 1: Get Your State License

Every state requires a home health agency to hold a state license before applying for Medicare certification. Fees, forms, and processing times vary widely, so the first call is to your state health department or licensing authority.

A few examples show the range:

Pennsylvania: an agency must meet the definition in PA Code 28 §601.6 — an organization staffed and equipped to provide skilled nursing and at least one other therapeutic service — and hold a license from the Pennsylvania Department of Health before applying for federal certification.⁴
Indiana: applicants submit State Form 4008 with a $250 fee, articles of incorporation, IRS tax documents, staff licenses and resumes, and criminal background checks.⁵
Texas: agencies must license as a Home and Community Support Services Agency (HCSSA), which involves pre-survey computer-based training, registration with the Secretary of State and the Comptroller, and an initial fee of $2,625 for a three-year parent agency license.⁶

Across states, the common thread is that the agency must be primarily engaged in providing skilled nursing care plus at least one other therapeutic service: physical therapy, occupational therapy, speech-language pathology, medical social services, or home health aide services.⁷

Step 2: Enroll With Medicare

Once you hold the state license, you file the Medicare enrollment application on CMS Form 855A, the form used by institutional providers. Submit it through the Provider Enrollment, Chain, and Ownership System (PECOS) or on paper to your Medicare Administrative Contractor (MAC). Online submissions typically process faster.⁸

Before applying, get a Type 2 National Provider Identifier through the National Plan and Provider Enumeration System.⁹ The 2026 application fee is $750.¹⁰ You’ll also need an Electronic Funds Transfer authorization (CMS-588), a Health Insurance Benefit Agreement (CMS-1561), and civil rights certification documents.⁵ The MAC can request additional documentation at any time, and you have 30 days to provide it.¹¹

A surety bond is also required. The minimum is $50,000, or 15 percent of the annual Medicare payments on the most recently accepted cost report — whichever is greater. A brand-new agency has no cost report history, so the $50,000 floor applies. The bond has to be in effect from the start date of the provider agreement; failing to maintain it is grounds for CMS to refuse or terminate the agreement.¹²

Step 3: Build a Patient Census Before the Survey

This is where many new agencies get caught off guard. Before an initial certification survey can happen, the agency must have already served at least 10 skilled patients, and at least 7 of them must be actively receiving skilled care at the time of the survey. In a medically underserved area (verified through the HRSA MUA database), the threshold drops to 5 patients, with at least 2 active on the day of the survey.¹³

These patients don’t need to be Medicare beneficiaries. Private pay, Medicaid, and other payer sources all count so long as the care is skilled and consistent with the Conditions of Participation.¹³ The agency also has to be demonstrably providing skilled nursing plus one more therapeutic service.¹⁴ Practically, that means running without Medicare revenue during the ramp-up. Plan the cash flow around it.

Step 4: Pass the Initial Certification Survey

Once the MAC approves the enrollment application and the census is in place, the initial certification survey follows. You have two paths.

The State Survey Path

The state survey agency (acting for CMS) sends a team that includes at least one registered nurse to evaluate compliance with all Conditions of Participation.¹³¹⁴⁶

The Accreditation Path (Deemed Status)

The alternative is accreditation from a CMS-approved accreditor with deeming authority: the Joint Commission, the Accreditation Commission for Health Care (ACHC), or the Community Health Accreditation Partner (CHAP).⁴ Accreditation by one of these organizations serves as a recommendation for Medicare certification because CMS has determined their standards meet or exceed federal requirements. CMS keeps final decision authority and can still run random validation surveys.¹⁵

Many new agencies choose accreditation, particularly in states with state survey backlogs. ACHC has held CMS deeming authority since 2006 and received a renewal through 2031.¹⁶ Accreditor fees depend on agency size, patient census, and number of locations. Published estimates put ACHC’s all-inclusive fees at roughly $2,500 to $10,000; the Joint Commission uses tiered annual fees that can run from about $25,200 to $37,800 depending on volume of activities.¹⁷ Many states also accept accreditation in lieu of routine state licensure inspections, which can simplify ongoing compliance.¹⁵

Realistic Timeline

CMS publishes approximate processing times for each step of institutional provider enrollment:

MAC initial review: about 30 days for online submissions, about 65 days for paper.¹⁸
State agency or accrediting organization review: about 45 days once a complete packet is received, including the survey itself.¹⁸
Secondary MAC review: about 10 days if no site visit is required, or 45 days if one is.¹⁸
CMS provider enrollment review: about 30 days.¹⁸
Final approval: about 3 to 10 days.¹⁸

Stacked end to end, that suggests roughly four to six months from enrollment application to certification when nothing slips. The state licensing period beforehand, the time needed to build the required census, and any state survey backlog can push the real total well past that. Texas, for instance, has up to 45 days just to process a complete HCSSA license application, and incomplete applications trigger an additional 30-day correction window.⁶

What the Survey Checks: Conditions of Participation

The Conditions of Participation at 42 CFR Part 484 are the federal health and safety standards every home health agency must meet at survey and maintain afterward.¹⁹ The major areas surveyors look at:

Patient rights. Agencies must provide written notice of rights, transfer and discharge policies, and the administrator’s contact information during the initial evaluation visit. Patients have the right to participate in their care plan, consent to or refuse care, and be free from abuse, neglect, and discrimination.²⁰
Care planning. Each patient must have an individualized written plan of care established by a physician or allowed practitioner covering diagnoses, prognosis, required services, medications, safety measures, and measurable goals. The plan must be reviewed no less often than every 60 days.²¹
Quality Assessment and Performance Improvement. Agencies must maintain a data-driven QAPI program that tracks quality indicators, identifies deficiencies, and drives improvement.²²
OASIS data submission. Patient assessment data (OASIS) must be electronically transmitted to CMS within 30 days of each assessment. New agencies must demonstrate they can submit OASIS data using CMS’s validation utility tool.²³⁵
Infection control and emergency preparedness. Both programs are required.²⁴

Staffing

Under 42 CFR §484.115, agencies must employ qualified personnel in several key roles.²⁵ The administrator, if hired on or after January 13, 2018, must be a licensed physician, a registered nurse, or hold an undergraduate degree; in all cases they need experience in health service administration and at least one year of supervisory or administrative experience in home health or a related program. The clinical manager must be a licensed physician, registered nurse, physical therapist, speech-language pathologist, occupational therapist, audiologist, or social worker. Registered nurses must have graduated from an approved school of professional nursing and be licensed in the state where they practice; LPNs work under RN supervision. Therapists (PT, OT, SLP) must hold the appropriate graduate-level degrees and state licenses specified in the rule. Social workers need a master’s or doctoral degree from a Council on Social Work Education–accredited school and one year of social work experience in a health care setting. Home health aides must meet the qualifications in 42 CFR §484.80, including training and competency evaluation.

After Certification: Staying Compliant

Certification is not a one-time event. OASIS data collection became an all-payer requirement as of July 1, 2025, meaning agencies submit assessment data to CMS’s iQIES system regardless of who is paying for the patient’s care. The quality reporting compliance threshold is 90 percent. Miss it, and CMS reduces your annual home health market basket increase by two percentage points.²⁶

Recertification surveys must occur no later than 36 months after the last standard survey and are unannounced. If surveyors find noncompliance with core standards, the survey can escalate to a partial or full extended survey covering all 15 CoPs, which must be completed within 14 calendar days.¹³

Fraud and abuse compliance sits alongside all of this. The Anti-Kickback Statute at Section 1128B(b) of the Social Security Act makes it a felony to knowingly offer, pay, solicit, or receive anything of value to induce referrals for services reimbursable by Medicare, with fines up to $25,000, up to five years in prison, and possible OIG exclusion from federal health care programs.²⁷ CMS uses Unified Program Integrity Contractors to detect and investigate fraud and can impose corrective action plans, payment suspensions, civil monetary penalties, and program exclusion.²⁸ The moratorium itself is CMS’s response to fraud concerns in the sector, so building an internal compliance program from day one is a reasonable investment.

1
Federal Register. Medicare, Medicaid, and Children’s Health Insurance Programs: Announcement of Nationwide Temporary Moratorium
2
CMS. QSO-26-11-HHA and Hospice Memorandum
3
Federal Register. CMS-6101-N: Nationwide Temporary Moratorium on HHA Enrollment
4
Pennsylvania Department of Health. Home Health Licensure
5
Indiana Department of Health. Home Health Agency Licensing and Certification Program
6
Texas Health and Human Services. How to Become a Licensed HCSSA Provider
7
CMS. Home Health Agencies
8
CMS. Enrollment Applications
9
PECOS. PECOS Provider Enrollment Portal
10
CMS. Fee Payment Welcome
11
CMS. CMS-855A Medicare Enrollment Application
12
eCFR. 42 CFR Part 489, Subpart F: Surety Bond Requirements for HHAs
13
CMS. State Operations Manual, Appendix B: Home Health Agency Survey Protocol
14
Michigan LARA. Home Health Agency Licensing and Certification
15
The Joint Commission. Deemed Status
16
ACHC. Home Health Accreditation
17
Integral Healthcare Solutions. Home Health and Hospice Accreditation
18
CMS. Provider Enrollment and Certification Roadmap
19
eCFR. 42 CFR Part 484: Home Health Services
20
eCFR. 42 CFR Part 484 – Section 484.50
21
Cornell Law Institute. 42 CFR 484.60: Condition of Participation – Care Planning, Coordination, and Quality of Care
22
eCFR. 42 CFR Part 484 – Section 484.65
23
eCFR. 42 CFR Part 484 – Section 484.45
24
eCFR. 42 CFR Part 484 – Sections 484.70 and 484.102
25
Cornell Law Institute. 42 CFR 484.115: Condition of Participation – Personnel Qualifications
26
CMS. Home Health Quality Reporting Requirements
27
HHS OIG. Medicare and State Health Care Programs: Fraud and Abuse; OIG Anti-Kickback Provisions
28
CMS. Medicare Program Integrity Manual, Chapter 4