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, which imposed a home health agency licensure moratorium from June 29, 2026 until no later than 90 days after the revised required regulations take effect. CDPH cannot issue new initial licenses or approve branches without the specified written unmet-need finding based on geographic concentration. It must stop processing new-license applications not licensed by June 29. Applicants with then-pending applications must respond by October 9, an upcoming date in this October 4 edition, through withdrawal, an exception justification with supporting evidence, or the stated intent to continue a change-of-ownership process. CDPH otherwise automatically withdraws the application. Changes of ownership within five years of initial licensing require an exception for continuity of care or both financial hardship and unmet geographic need. The letter also addresses exception requests for later applicants, geographic changes and branches, while preserving ordinary renewals and specified other changes.

Agencies must have an administrator and designee and a director of patient care services and designee. For each, the required HS 215 A or successor, resume and list of current management roles are due at application, within 10 business days of a personnel change, and once for currently licensed agencies by March 31, 2027; parent-agency branch offices are exempt from these management filings. Private-HHA applicants must provide fingerprints for persons with at least a five-percent ownership interest. Expanded denial, suspension or revocation grounds include specified prior program termination or license action, a pattern of violations over three years, the applicant’s or licensee’s exclusion-list presence, management noncooperation and unreported ownership, personnel, service-area or location changes. The AFL also addresses provisional-license renewal limits. The ownership fingerprint threshold and exclusion-list grounds are separate provisions.

Why it matters

Pending applicants and currently licensed agencies have different filing owners and dates. Transaction planning must also account for the five-year ownership restriction, while management changes and exclusion-related licensing risks continue independently of either one-time deadline.

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 2026-09-06
• CDPH all-facility-letter listingOfficial · California Department of Public Health · Source review 2026-09-06