California imposes a home health agency licensure moratorium under Senate Bill 164, with pending applicant responses due October 9, 2026 and management personnel filings due March 31, 2027

What happened

CDPH’s August 27 All Facilities Letter 26-28 explains SB 164, Chapter 27, and the home health agency licensing moratorium that began June 29. The moratorium lasts until no later than 90 days after the required revised regulations take effect. It bars new initial licenses and branch approvals unless CDPH makes the specified written unmet-need finding based on existing services in the proposed area. Applications not licensed by June 29 stop processing. CDPH is contacting those applicants: by October 9 they must indicate withdrawal, provide an exception justification and supporting documentation, or state the applicable intent to continue a change-of-ownership process. Without the required response, CDPH automatically withdraws the application. Ownership changes within five years of initial licensure need an exception for continuity of care or both financial hardship and unmet geographic need. New applicants should seek an exception before applying; ordinary renewals and specified changes that do not expand the service area remain outside the moratorium.

The letter separately requires an administrator and designee and a director of patient care services and designee. Their HS 215A or successor forms, resumes and current management roles must be submitted at application, within ten business days of a personnel change, and once for currently licensed agencies by March 31, 2027. Parent-agency branch offices are exempt from those management filings. Private-agency applicants must provide fingerprints for people with at least a five-percent ownership interest. Expanded licensing-action grounds include specified prior Medicare or Medi-Cal termination or license action, a pattern of violations within three years, applicant or licensee exclusion-list status, management noncooperation with inspections or complaints, and unreported ownership, personnel, service-area or location changes. CDPH also cannot renew a provisional license that lacks the required full-licensure standards. These personnel, ownership and enforcement provisions require separate review from an application’s moratorium exception.

Why it matters

The licensing moratorium and management disclosures are separate obligations. Then-pending applications have specific response routes, while parent-agency branch offices are exempt from the management-personnel filings. The five-percent ownership threshold concerns fingerprints; the listed exclusion ground concerns the applicant or licensee, rather than creating that same threshold for every screening duty.

Sources

• All Facilities Letter 26-28, Senate Bill 164, Home Health Agency Licensure: Moratorium on New Licenses and Expansion of Licensure RequirementsOfficial · California Department of Public Health, Center for Health Care Quality · 2026-08-27 · Source review 2026-08-31
• All Facilities Letters, 2026 indexOfficial · California Department of Public Health, Licensing and Certification Program · Source review 2026-08-31