Licensing in All 50 States? What Prospective Agency Owners Should Ask

When choosing a healthcare licensing consultant, you may see statements such as “We provide licensing in all 50 states.” National experience can be valuable...but it is not the same as every license being available to every applicant in every state.

Home care, home health, and hospice licensing is state-specific. Some states accept new applicants on an ongoing basis. Others require a Certificate of Need. Some accept applications only when the state has identified a need for additional providers. At times, a particular state or federal enrollment pathway may be temporarily closed.

No single healthcare licensing pathway is continuously open to every applicant in all 50 states. Understanding that distinction is part of understanding healthcare licensing.

Why “all 50 states” needs context

A consultant can certainly work nationally. A national consultant may research requirements, prepare applications, develop policies, respond to deficiencies, and guide providers through processes in many different states.

But that is different from saying a new home care, home health, or hospice agency can be licensed in every state at any given time. Availability may differ by provider type, county, service area, ownership structure, or program.

Before an application is prepared, the first question should be: Is this specific license or enrollment pathway currently available where the client wants to operate?

Certificate of Need changes the conversation

A Certificate of Need, commonly called a CON, is a state healthcare planning mechanism. Instead of allowing every qualified applicant to open a new provider, a state may first determine whether another provider is needed. Depending on the state and provider type, CON approval may be required before the ordinary licensing process can move forward.

That means the question is not simply whether the application can be completed. It is whether the proposed agency can satisfy the state's need determination and any geographic restrictions.

Examples of state-specific pathways

North Carolina

North Carolina's State Medical Facilities Plan uses policies and methodologies to determine need for specified healthcare facilities and services. Those projections include Medicare-certified home health agencies and hospice services. If the plan does not identify a need for the proposed service and area, the ordinary application path may not be available.

Kentucky

Kentucky's home health provider guidance directs prospective providers to the Office of Inspector General for both a Certificate of Need and a state license. That is a different pathway from simply filing a license application.

New York

New York applies public-need review to Licensed Home Care Services Agency applications. Its regulations establish a rebuttable presumption that additional agencies are not needed in certain planning areas when the existing provider threshold has been met.

West Virginia

West Virginia maintains a Certificate of Need program and publishes separate need methodologies for home health and hospice services. A project must be evaluated against the requirements and exemptions that apply to its specific service.

Vermont

Vermont's home health system uses designated geographic service areas. The state's structure is not a conventional open-entry environment in which a new applicant can simply select any territory and file an ordinary application.

Sometimes a specific pathway is temporarily closed

Certificate of Need is not the only possible barrier. A state or federal agency can impose a moratorium or temporarily stop accepting a particular category of application.

California

Effective June 29, 2026, California placed a moratorium on new Home Health Agency licenses. During the moratorium, the state generally cannot issue a new initial HHA license or approve a new branch, although the law provides a limited exception process based on demonstrated unmet need.

Georgia

For Georgia's April 2026 review cycle, the state announced that it would not accept or review Certificate of Need applications for new or expanded home health services because its methodology did not identify a need. The state scheduled the next need assessment for approximately September 30, 2026.

State licensure and Medicare enrollment are not the same

Obtaining a state license does not necessarily mean an agency can immediately become a Medicare provider. State licensure, Certificate of Need, accreditation, Medicare certification and enrollment, Medicaid enrollment, and payer contracting are related...but they are not interchangeable.

As of September 2026, CMS has a temporary nationwide Medicare enrollment moratorium for new Home Health Agencies and Hospices that began May 13, 2026. It applies to new initial Medicare enrollments and certain changes in majority ownership. A state licensing pathway may therefore be open while the corresponding federal enrollment pathway is not.

What “national” should mean

There is nothing wrong with saying a company provides national licensing support. To us, national experience means knowing how to approach different regulatory systems, identify the requirements that apply, recognize special approval processes, and tell a prospective agency owner when the pathway under consideration is not currently available.

Sometimes good guidance means helping a client complete an application. Sometimes it means explaining that a Certificate of Need must come first. And sometimes it means saying: You cannot open that type of agency in that location right now.

That conversation may not result in an immediate sale, but it may save the prospective agency owner thousands of dollars and months of work.

Questions to ask before hiring a licensing consultant

If a consultant advertises licensing in all 50 states, consider asking:

• Is my specific license type currently available in the state where I want to operate?
• Does my state require a Certificate of Need?
• Is there currently a moratorium or another restriction on new applications?
• Is availability determined by county, service area, or another geographic planning area?
• Are you discussing state licensure, Medicare certification, Medicaid enrollment, or all three?
• Have you verified the current requirements for my agency type rather than relying on a standard national process?

A knowledgeable consultant should be comfortable answering those questions...including when the answer is no, not yet, or not in that service area.

Experience is more than a state count

Healthcare licensing experience should not be measured only by how many states appear in a marketing statement. It should be measured by whether the consultant understands that 50 states means 50 different regulatory environments...and knows when a client should move forward, when additional approvals are necessary, and when the most responsible advice is not to proceed.

At SouthStart | NorthEnd, we work nationally across home care, home health, and hospice, but we do not assume that every licensing pathway is available everywhere. We evaluate the agency type, state, services, regulatory pathway, and current licensing environment before determining the appropriate next step.

Because knowing how to prepare an application is important. Knowing whether the application can be filed in the first place is just as important.