Buying a Home Health Agency After the Moratorium
Licenses just got scarcer and the 36-month ownership rule reshapes deals. Two kinds of markets, two operating plans, and the first ninety days after close.
The CMS enrollment moratorium changed the value of an existing home health or hospice license overnight, and it changed it in two directions at once. If you own one, it just became scarcer. If you want one, the only way in is to buy one that already exists, and even that path now has a tripwire: a change of majority ownership within 36 months of enrollment, or of the last ownership change, blocks re-enrollment while the freeze holds.
So the deal flow in home-based care is about to concentrate on mature licenses, and the operators who buy them will be integrating branches, rosters, and referral relationships in markets that are all growing, but not all growing the same way. This post is for the people making those decisions: what to look at in a market before you buy, and what has to be true in the first ninety days after you do.
First, the demand you are buying into
National demand is not in question. Aging the Census Bureau's population projections through MedPAC's observed use rates, home health visits grow about 30 percent and hospice days about 32 percent from 2026 to 2036, with the 80-plus population up 56 percent. Supply is frozen at 12,234 home health agencies and 6,706 hospices, and new branches cannot enroll either. Whatever you buy will be asked to carry roughly a third more work through the same front door. Sources and the open model are on our Data and Sources page.
What differs market to market is how that growth arrives, and it sorts into two kinds of markets that call for two different operating plans.
Tight-base markets: few licenses, heavy loads
Some metros already run far more visits per agency than the national average, because provider counts are low relative to the population. In those markets an existing license carries real leverage: demand walks in the door, and the constraint is not winning patients but serving them well enough that referral partners keep sending them.
The referral partners have their own scoreboard. Hospitals carry penalties on 30-day unplanned readmissions, and Medicare Advantage plans and Home Health Value-Based Purchasing score what happens in the weeks after discharge. An acquired agency in a tight market wins by protecting that window: same-day acceptance, a documented first contact within hours of discharge, and check-ins that catch a problem before it becomes an emergency department visit. Our Readmission Reduction bundle is built for exactly that handoff, and the acute-care exposure calculator shows what each prevented event is worth. Post-discharge follow-up is also now a first-class part of our pricing model, because value-based contracts increasingly require it.
Deep-base markets: many licenses, fast growth
Other metros, particularly across the Sunbelt, have plenty of providers and modest loads today, but growth fast enough that loads still rise sharply by 2036. There, an acquisition is a share and density play. You are not the only agency a referral source can call, and you are not the only agency a family can review.
Two things separate agencies in a crowded market. The first is experience families talk about: HHCAHPS carries 20 percent of the HHVBP total performance score, and public reviews are how a family chooses between four agencies with the same star rating. Inviting every family to leave a review, never selectively, is both the compliant path and the one that builds a defensible reputation; that is what patient reviews in Quincy automates. The second is reach: Sunbelt growth is Spanish-speaking growth, and an agency that can engage families in their language by text, with real-time translation for staff, serves a census its competitors cannot.
The first ninety days after close
Every roll-up we have watched succeed or stall came down to communication plumbing in the first quarter. Three things to insist on:
One team platform across every branch on day one
Acquired branches arrive with their own texting habits, on-call sheets, and phone trees. Until they share one secure messaging platform, one on-call schedule, and one directory, every cross-branch referral is a phone call that may or may not get returned. QliqCHAT is the layer we deploy across multi-branch organizations; our multi-service line page describes how it spans home health, hospice, and personal care under one roof.
Patient engagement that does not depend on which EMR a branch runs
Acquisitions rarely land on a single EMR in the first year. Family engagement that runs off standard integrations, including log-shipped feeds from Homecare Homebase, lets you standardize the patient-facing experience across branches before the back office is unified.
Retention through the transition
Turnover spikes after a change of ownership, and at 75 percent baseline turnover the industry has no slack for that. Scheduling that respects people, safety tools for lone workers, and communication that reaches field staff without a phone tree are the difference between inheriting a roster and inheriting a vacancy list. The turnover calculator puts a dollar figure on retaining one in five.
A note on the 36-month rule
The moratorium's ownership provision is a diligence item, not a footnote. A license enrolled or last transferred inside 36 months cannot re-enroll after a majority change while the freeze holds. That raises the premium on mature, stable licenses and lengthens the timeline on recently flipped ones. Talk to counsel before you talk to a broker. Our reading here is operational, not legal advice.
The freeze will lift eventually. The demographics will not reverse. Buyers who use this window to build one operating platform across the licenses they acquire will own the capacity everyone else is trying to enroll.
Can I buy a home health agency during the CMS moratorium?
Enrolled agencies can be acquired, but re-enrollment after a change of majority ownership within 36 months of initial enrollment or the most recent ownership change is blocked while the moratorium holds. Mature licenses with stable ownership are the ones that transfer cleanly. Confirm specifics with counsel.
What is the difference between a tight-base and a deep-base market?
Tight-base markets have few providers relative to demand and high visits per agency, so an existing license absorbs growth and the job is serving referral partners well. Deep-base markets have many providers and modest loads but fast growth, so the job is share, experience, and reach.
What should be standardized first after an acquisition?
Team communication: one secure messaging platform, one on-call schedule, one directory across all branches. Patient and family engagement can then be standardized through integrations before the EMR footprint is unified.
Founder & CEO of QliqSOFT. Building healthcare communication solutions for 12+ years. Focused on closing gaps in care through technology that enhances human connection.
