Healthcare

HHS/CMS 2026: Compliance Goalposts Continue to Move Closer

February 18, 2026
By
Wil Yu, Regology Healthcare Lead
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Healthcare compliance is now operating in a more enforcement-focused and outcome-driven phase.

There is ample evidence from recent Federal behavior that a new era of heightened accountability is unfolding. HHS and CMS have moved away from extended guidance and interpretation periods toward tighter alignment timelines, outcomes-based oversight, and a greater willingness to enforce when expectations are not met. For compliance teams, the distance between regulatory change and regulatory consequence has meaningfully narrowed.

That shift became especially clear in recent weeks. CMS Administrator Mehmet Oz released a new HHS legal team recruiting message in support of increased program enforcement and investment. Days earlier, the Office of the Inspector General released updated Industry-Specific Compliance Guidance for Medicare Advantage, reinforcing expectations around governance, monitoring, and accountability.

Together, these signals confirm what many compliance leaders are already experiencing in practice: enforcement is no longer a downstream consideration. In 2026, it is an active and immediate part of the regulatory landscape, requiring faster alignment, stronger monitoring, and clearer evidence that controls are working as intended across both internal operations and delegated entities.

From Guidance-Centric Oversight to Outcome Accountability

This shift did not emerge overnight.

For years, healthcare regulation operated with an implicit buffer between new requirements and meaningful enforcement. Guidance documents, interpretive flexibility, and phased remediation allowed organizations time to absorb change and demonstrate progress.

That buffer is eroding.

What regulators are now signaling is a preference for observable outcomes over stated intent. The question is no longer whether an organization understands its obligations, but whether its controls are producing the expected results in practice—and doing so consistently.

For compliance leaders, this changes the nature of the work and its outcomes. Interpretation remains important, but it is no longer sufficient. Alignment must be timely, operationalized, and defensible in real time.

Enforcement Capacity Is Being Built Deliberately

The expansion of HHS’s legal and enforcement capabilities should be viewed as structural rather than symbolic.

Investing in enforcement personnel, modernizing audit logistics, and issuing more targeted compliance guidance all point to a regulatory apparatus designed for greater throughput and faster follow-up. Oversight is becoming more scalable, more data-driven, and less dependent on lengthy retrospective reviews.

This posture aligns with earlier signals, including CMS’s 2026 Program Audit Updates memo from last November, which introduced changes to audit scoring, condition classification, and field operations. While those updates emphasized efficiency and consistency, they also reflected a deeper shift: audits are expected to move more quickly from identification to remediation, with fewer opportunities for prolonged ambiguity.

The result is a compliance environment where expectations are clearer, and patience for delay is thinner.

What Modernized Audits Mean for Compliance Teams

As CMS continues to refine audit field operations, the emphasis is increasingly on data integrity, control effectiveness, and demonstrable remediation.

Administrative noise is being stripped away in favor of clearer findings and more direct corrective pathways. At the same time, the volume of audits is expected to increase, placing additional pressure on organizations to maintain readiness across lines of business.

In this model, compliance maturity becomes visible. Organizations with strong governance structures, continuous monitoring practices, and well-defined accountability—both internally and across delegated entities—are better positioned to respond calmly and consistently.

Those relying on episodic reviews or fragmented oversight will find it harder to keep pace.

The Narrowing Compliance Window

One of the most important results of this shift is the shrinking window between regulatory expectation and consequence.

Where compliance teams once had ample time to observe how guidance was interpreted across the market, that wait-and-see period is shortening. Enforcement is increasingly black and white: controls are either effective or they are not; remediation is either timely or it is not.

This is especially apparent in high-priority operational areas such as Medicare Advantage risk adjustment, supplier standards, and fraud, waste, and abuse controls—domains where CMS and HHS are leveraging advanced analytics and AI-driven detection to surface issues quickly.

In this new landscape, retrospective explanations carry less weight than present-day operational reality.

What 2026 Demands from Compliance Leadership

For compliance leaders, the implications are operational as much as they are regulatory.

This moment requires faster internal alignment, clearer decision pathways, and stronger evidence of ongoing monitoring. Teams must be able to translate regulatory change into operational expectations quickly and verify that those expectations are being met across internal business units, vendors, and delegated entities.

It also requires a shift in mindset. Compliance can no longer be structured around periodic validation alone. Continuous visibility into regulatory change, policy alignment, and control performance is becoming essential.

Organizations that treat enforcement readiness as an ongoing state rather than an episodic exercise will be better equipped to operate without constant escalation.

What the Data Confirms: Enforcement Is Becoming Systemic

The tightening compliance window described above is not just a forward-looking concern. It is already showing up in how regulators are signaling priorities and how enforcement is being applied across the healthcare ecosystem.

Regology tracks regulatory change, guidance, and enforcement activity across healthcare, and what we’re seeing as 2026 unfolds confirms this shift in real time. Enforcement activity is becoming more proactive, more data-driven, and less tolerant of delay or ambiguity, mirroring the enforcement-first posture emerging from HHS and CMS. 

Regology expects this trend to intensify through 2026 as HHS continues its move toward immediate, binary audit standards, replacing slower, retrospective review models.

In practice, Regology healthcare clients are already seeing increased sensitivity to enforcement priorities, including:

  • Stricter enrollment and ownership scrutiny, particularly for SNFs, HHAs, and DME suppliers;

  • Cross-program termination enforcement, linking Medicare actions directly to Medicaid and CHIP participation;

  • Heightened scrutiny of Medicare Advantage provider directory accuracy, extending compliance pressure to providers and delegated entities;

  • Increased focus on data integrity, including provider identifiers, practice locations, ownership and control interests, and effective dates.

Together, these developments reinforce a broader shift away from “best-effort compliance” toward auditable, system-validated compliance. The pathway to meeting regulatory expectations is becoming more direct—and less forgiving.

A clear example is the proposed CY2027 Advance Notice of Medicare payment policy, which introduces linked chart review requirements for risk score calculations—best read as an enforcement signal, not a technical adjustment.

A Measured but Meaningful Evolution

Despite the heightened focus on enforcement, this is not a chaotic or punitive shift.

What is unfolding at HHS and CMS reflects a rational evolution toward proactive, outcomes-driven oversight—one that prioritizes clarity, consistency, and timely correction as opposed to prolonged interpretation.

For compliance leaders, the signal is not an alarm, but accountability.

The goalposts are closer. Expectations are clearer. And the opportunity in 2026 lies in adjusting operating models to reflect this reality—building compliance programs that are not only responsive, but resilient.

Those who do will find that even in a more exacting environment, compliance can be steadier, more predictable, and ultimately more effective.


Read more from the Healthcare rubric:

Decision Time Is the New Compliance Risk: 2026 in Healthcare

After the Rush: OBBBA Forces Healthcare Compliance to Get Precise

Out of the Weeds: Automating Routine Tasks to Free Up Healthcare Compliance Teams

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