Lexology December 19, 2025
Providers and suppliers participating in the Medicare program should take note of new requirements and compliance considerations related to Medicare enrollment, information updates, changes of ownership, and increased risk for revocation, set to take effect on January 1, 2026. The most consequential changes are found in the CY 2026 Home Health Agency Prospective Payment System (HH PPS) final rule (“Final Rule”), which was published on December 2, 2025.[1] In this Final Rule, Centers for Medicare & Medicaid Services (“CMS”) finalized substantial expansions to its authority to retroactively revoke enrollment for all types of Medicare providers and suppliers, including hospitals, hospices, and home health agencies to physician practice groups and DMEPOS suppliers related to Medicare enrollment and compliance deficiencies. CMS also...
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