If your plan was to open a Medicare-certified home health agency or hospice this year, the ground has shifted. On May 13, 2026, CMS paused new Medicare enrollment for home health agencies and hospices nationwide. The freeze runs for an initial six months, to mid-November 2026, and CMS can extend it. But that pause is not a reason to wait. It’s a reason to start in the right place, and for many new owners that place is private pay home care.
What’s still open: private pay and non-medical home care
The moratorium applies to Medicare enrollment. It does not touch the parts of the market where most new owners should begin anyway:
- State-licensed non-medical home care: personal care, personal assistance, homemaker-companion, and private home care, depending on your state.
- Private-pay services: families paying directly for care, with no Medicare billing involved.
- Medicaid and managed-care pathways in many states.
These routes are open today, and they carry a lower barrier to entry. They also let you start serving clients and generating revenue while the Medicare door is closed.
Which license private pay home care needs in your state
Private pay doesn’t mean unlicensed. Most states still license the agency, and the license name changes at every state line:
- Texas: a Home and Community Support Services Agency (HCSSA) license in the Personal Assistance Services (PAS) category, issued by HHSC. Our Texas licensing guide walks through it.
- Georgia: a Private Home Care Provider (PHCP) license from the Healthcare Facility Regulation Division, with no Certificate of Need involved.
- California: a Home Care Organization (HCO) license from the Department of Social Services.
- Florida: a Homemaker and Companion registration covers non-medical companion services only. Hands-on personal care needs a full Home Health Agency license from AHCA, as our Florida licensing guide explains.
- Michigan: no state license for non-medical home care, although business and insurance requirements still apply, plus Medicaid EVV rules if you bill Medicaid.
Not sure where your state falls? Our guide to states that don’t require a home care license covers the traps that catch new owners.
Why starting with private pay home care is often smarter
Even without a moratorium, building a strong private-pay or non-medical operation first is often the better way in. You learn your market and build referral relationships. Along the way, you prove your care model and establish clean documentation, all before you take on the weight of Medicare certification. Then, when enrollment reopens, you move from a position of strength rather than starting cold.
Use this window to get ahead
When the freeze lifts, new applicants will face the highest level of screening for six months. So the agencies that move fastest will be the ones that are already audit-ready: clean structure, complete policies, and documentation that holds up to scrutiny. This window is for preparation, not idling. Our article on getting ready before the freeze ends sets out what to do in what order.
Get the order right
The most expensive mistake we see is spending money in the wrong sequence: chasing a certification that’s paused, or a license your state doesn’t even issue. A clear roadmap for your state and service type fixes that before it costs you months.
That’s exactly where we help. We tell you plainly what you can launch now, what to prepare for later, and how to be first in line when Medicare enrollment reopens. Every one of our license packages has its price published up front, with no surprises.
Not sure what you can launch right now? Book a Discovery Call and we’ll map what’s open in your state and how to prepare for Medicare when it returns. If your situation isn’t a fit for us, we’ll tell you who can help.
This article is general information, not legal advice, and reflects the position as of October 2026. Moratorium dates and rules can change; we confirm the current status as part of every project.
