On July 30, 2026, effective immediately, the New York State Department of Health (DOH) imposed a six-month moratorium on new Medicaid enrollments and change-of-ownership (CHOW) applications for six provider categories identified by the State as presenting heightened program integrity concerns.

The moratorium applies to:

1. Laboratories;

2. Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers;

3. Applied Behavior Analysis (ABA) providers;

4. Licensed Home Care Services Agencies (LHCSAs);

5. Pharmacies; and

6. Managed Long Term Care (MLTC) plans.

According to DOH, enrollment and CHOW applications for these provider types will not be processed during the moratorium, including applications that are already pending. The State expects the moratorium to remain in effect for at least six months while it focuses on federally required Medicaid provider revalidation efforts.

The moratorium does not affect providers that are already enrolled in the New York Medicaid program. Existing providers should continue participating in Medicaid and receiving reimbursement without interruption.

The announcement has significant implications for healthcare providers and investors pursuing acquisitions, ownership transfers, or expansion into the affected provider categories. Transactions that require Medicaid enrollment or CHOW approval are likely to be delayed, and parties should carefully evaluate whether transaction timelines, closing conditions, or deal structures should be adjusted.

For LHCSA transactions, it also remains unclear whether related approval processes, including Schedule 1 review, will be impacted. Additional guidance from DOH is expected in the coming days.

Organizations considering new Medicaid enrollments or transactions involving any of the affected provider categories should promptly assess how the moratorium may affect their plans. We will continue monitoring developments and will provide updates as additional guidance becomes available.