“Healthcare agency” can describe very different transactions. A buyer may be evaluating an operating company, selected assets, or an entity with particular licenses and payer relationships. Before you describe your acquisition criteria, identify which operating capabilities you need to continue at closing.
Separate the layers.
State licensure, Medicare enrollment, accreditation and payer contracts deserve separate questions. Ask what the proposed transaction includes and which approvals, notices or applications the buyer would need. A statement about one layer does not establish the status of the others. Request supporting records through the advisor’s approved diligence process.
Check current ownership rules early.
As checked on October 24, 2026, CMS reports a temporary nationwide enrollment moratorium for home health agencies and hospices, implemented May 13, 2026. CMS says it applies to initial applications, including non-exempt changes in majority ownership under 42 CFR 424.550(b), and that affected applications submitted after implementation will be denied. CMS describes a six-month period with possible extensions.
That scope matters. The announcement does not establish whether a particular proposed acquisition is exempt or approvable. Ask qualified healthcare counsel and the relevant enrollment authorities to evaluate the ownership history, deal structure and current rules before relying on an operating timeline. Recheck the linked CMS guidance when evaluating a transaction.
Put the right questions in your brief.
- Do you need an operating agency with staff, contracts and infrastructure, or are you willing to build those capabilities?
- Which certifications and payer relationships are essential to your plan?
- What is your relevant operating experience, and who will lead compliance?
- How much flexibility do you have if approvals or transition work take longer?
A clear brief helps an advisor understand fit without assuming that a license, enrollment or referral relationship will transfer. This resource provides general preparation questions; it is not legal advice or a determination about any transaction.