A Health System Just Showed Its Playbook for Growing During the Moratorium: What CommonSpirit's Three Pillars Teach Independent Owners
CommonSpirit Health at Home had to rethink growth when the CMS enrollment moratorium put its de novo plans on hold. Its three pillars offer independent owners a useful lens for building density, strengthening referral relationships, and identifying care needs earlier. This article also explains which advantages come from CommonSpirit’s health system structure, why technology adoption takes work, and how documented, durable operations can support buyer confidence.
10/26/20267 min read
This article looks at how CommonSpirit Health at Home adjusted its growth plans after a CMS enrollment moratorium put its de novo strategy on hold. For independent home health or hospice owners, its three-pillar approach offers practical ideas to consider, though a smaller agency cannot simply copy a health system’s advantages.
Quick-Scan Summary
Who this is for
Owners of home health or hospice agencies with $2 million to $10 million in revenue.
Operators weighing growth, succession, or a future sale.
Leaders looking for ways to grow within existing markets while the moratorium remains in place.
Key takeaways
CommonSpirit Health at Home described its growth strategy as geographic expansion, increased market share, and engaging patients farther upstream.
The moratorium prompted a pivot from a strategy that relied heavily on new locations. The company is focusing on opportunities in markets where it already operates.
Independent agencies can apply the underlying ideas by building local market density, developing referral relationships, and creating documented processes for identifying patients who may qualify for care.
A health system’s joint ventures and internal relationships are structural advantages, not a ready-made playbook for a standalone agency.
Technology may support capacity and clinician experience, but a tool’s potential is not the same as proven, sustainable earnings.
What CommonSpirit announced, and why the pivot matters
CommonSpirit Health at Home’s five-year growth strategy has three pillars: geographic expansion, increasing market share, and engaging patients farther upstream. CEO Trisha Crissman told Hospice News that the strategy had been heavily focused on de novos, or new locations. With the CMS enrollment moratorium preventing those locations from moving forward, the company paused some plans and reconsidered how it could serve more patients in markets where it already operates.
The pause is not a cancellation of the company’s longer-term plan. Crissman said CommonSpirit expects to resume de novo expansion if CMS lifts the freeze. The moratorium is currently scheduled to end November 13, 2026, but CMS has the option to extend it. Owners should plan around the policy in effect, not assume that the scheduled date guarantees a change.
CommonSpirit operates within a much larger health system. It serves more than 16,000 patients across 15 states and has 15 joint ventures with regional hospital systems, according to Hospice News. For an independent owner, the useful lesson is not to imitate that scale. It is to ask which growth levers can work with the agency’s current staff, service area, and relationships.
Three pillars, translated for an independent agency
The table distinguishes CommonSpirit’s strategy from what an owner of a smaller agency might reasonably adapt. Technology supports the initiatives described in the reporting, but it was not presented as a fourth pillar.
What transfers: density, relationships, and documented processes
Build density before adding geography
When new locations are on hold, a smaller agency can review whether its current footprint is being used effectively. Start with service area, staffing coverage, referral volume, and operational capacity. If the agency already has room to serve additional patients nearby, improving local density may be more practical than spreading leadership and staff across another market.
This is not a promise that denser coverage will automatically improve margins. It is a way to focus growth efforts on places where the agency already has some operational presence and can measure what is working.
Develop referral relationships upstream
CommonSpirit is working with primary care providers and specialty clinics to identify patients who may qualify for home health, hospice, or palliative care before an acute exacerbation. In Home Health Care News, Crissman described this as establishing “proactive early identification of eligibility and transition pathways” with those providers.
A standalone agency can pursue the relationship-building part without a health system behind it. Identify two or three local clinics or physician groups whose patients may benefit from the services the agency actually provides. Offer practical education on eligibility, referral steps, and how the agency communicates with clinicians and families. The aim is timely access to appropriate care and informed conversations, not steering patients toward a particular service.
Make eligibility support repeatable
A relationship that depends on one owner or clinician is difficult to maintain through growth or a sale. Document how staff receive a referral, gather relevant information, communicate with the referring clinician, and help the patient and family understand available services. For hospice, that includes supporting appropriate goals-of-care conversations. It does not mean making clinical decisions for the patient or their treating providers.
What does not transfer as easily
CommonSpirit’s 15 joint ventures and broader health system relationships create access that an independent agency may have to build one connection at a time. Even within the larger system, Crissman said the home-based care division still has to educate internal stakeholders and advocate for its inclusion in value-based care contracts. Relationships do not connect themselves.
A standalone operator can approximate some of the work, though not the same scale, by maintaining consistent referral-source contact, building clinic partnerships, and offering community physician education. Track results by source: referrals, admissions, service type, and how much of the agency’s census depends on a small number of relationships. That helps distinguish a broad, developing referral base from growth that rests on one or two key people.
The technology lesson: test adoption, not just capability
CommonSpirit is using technology, including ambient scribing and AI-related tools, to reduce administrative burden, support clinician engagement, and expand capacity. But the Home Health Care News report also notes that ambient scribing adoption was slower than Crissman expected. The company is working with superusers to help clinicians become comfortable with it.
That is a useful caution for a smaller agency. Choose a specific workflow problem, involve the staff who do the work, and start with a small pilot and designated superusers. Track whether the tool is used consistently and whether it improves documentation time, referral management, clinician experience, or the capacity to serve patients. Crissman described a clinician finishing documentation in time to attend her son’s baseball game. It is an anecdote, not a promised result, but it reflects an important goal: technology should make the workday and patient interaction better, not just add another system to manage.
For a buyer, a documented process that supports capacity and reduces dependence on one person can be a positive underwriting signal. But a new tool, projected time savings, or unproven workflow change is not counted as established earnings simply because it could work. Evidence of consistent use and measurable operating results matters.
aluation and exit implications
For owners preparing for a sale or succession, a repeatable growth process can help a buyer understand how referrals are generated and whether the agency can sustain them. A concentrated census or referral base can raise questions about what happens if one source, physician relationship, or key employee leaves. A clear, documented playbook can help reduce uncertainty, although it cannot eliminate market or operating risk.
Here is an illustrative valuation scenario, not a market quote or a prediction of value:
The $350,000 difference shows why buyer confidence in the durability of earnings matters. The table does not suggest that a particular referral strategy or technology pilot will earn a specific multiple. Buyers examine the full business, including financial quality, workforce stability, payer and referral concentration, compliance, and whether the owner’s growth process can continue without depending on the owner alone.
What owners can do now
Map referral concentration by source and review how that connects to census and revenue.
Identify two or three clinics or physician groups for practical education about services, eligibility, and referral steps.
Document how staff support eligibility identification, transitions, and patient-centered goals-of-care conversations.
Pilot one technology with a small group of superusers. Define what improvement you will measure before expanding it.
Keep de novo plans flexible until CMS clarifies whether the moratorium will be lifted or extended.
Plain-Language Glossary
De novo: A new agency location or operation.
Moratorium: A temporary pause on specified activity, in this case new enrollment covered by the CMS freeze.
Upstream care: Identifying people who may qualify for support earlier, before an acute change or crisis.
Ambient scribing: Technology that helps capture visit documentation from a clinician-patient conversation.
Superuser: A staff member who learns a tool or workflow in depth and helps colleagues use it.
Joint venture: A business arrangement in which two or more organizations share ownership or responsibilities.
EBITDA: Earnings before interest, taxes, depreciation, and amortization.
Normalized EBITDA: EBITDA adjusted for unusual or non-recurring items to better reflect ongoing operations.
Multiple: A factor applied to a financial measure, such as EBITDA, to estimate business value.
Referral durability: How likely referral relationships are to continue over time, rather than depending on a single person or temporary circumstance.
So what should you do now?
Focus first on measurable growth within the markets you already serve.
Turn referral education and eligibility support into documented, repeatable workflows.
Test technology with the people who will use it, and verify the results before relying on projected gains.
Keep expansion plans adaptable while the moratorium’s status remains subject to CMS.
Explore a sale or partnership
Senate Healthcare LLC is the buyer and strategic partner pursuing home health or hospice agency acquisitions. We are not a broker or advisor. Your agency does not need to be perfectly positioned today to have a confidential conversation with us about reducing transition risk and exploring a sale or partnership.
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