CMS Introduces Probationary Prior Authorization for Newly Enrolled DMEPOS Suppliers

What You Need to Know

Effective October 15, 2026, CMS will implement a new oversight initiative known as the Probationary Prior Authorization (PPA) Program. Under this program, certain newly enrolled DMEPOS suppliers and suppliers experiencing specific ownership changes must obtain prior authorization before furnishing designated DMEPOS items to Medicare beneficiaries.

Who is affected?

• Newly enrolled DMEPOS suppliers with an effective date on or after October 15, 2026.
• DMEPOS suppliers that undergo a 100% change of ownership effective on or after October 15, 2026. 

What codes are included?

• Osteogenesis Stimulators: E0747 and E0748
• AFOs/KAFOs: L1902, L1906, L1971, L2035, L2132, L2134, L2136, L4360, L4361, L4396, and L4397
• Knee Orthoses: L1810, L1812, L1820, and L1821
• Lower Limb Orthoses: L1652, L1653, L1686, and L1690
• Spinal Orthoses: L0626, L0627, L0628, L0630, L0633, L0635, L0641, L0642, L0643, L0649, and L0720
• Upper Limb Orthoses: L3660, L3670, L3760, L3762, L3809, L3908, L3915, and L3960

*Note: CMS has the right to update the code list if new program vulnerabilities are identified

How long does PPA last?

• The one-year probationary period begins when a supplier submits their first claim for one of the DMEPOS items listed above.

How does the PPA Process Work?

• The PPA Program uses the same operational framework as Medicare's existing prior authorization process. Importantly, the new probationary requirement does not replace Medicare's current Prior Authorization Program. Existing prior authorization requirements remain in effect and continue to apply to all applicable DMEPOS suppliers.

What This Means for You

CMS's implementation of the Probationary Prior Authorization Program reflects the agency's continued focus on program integrity, supplier oversight, and fraud prevention in higher-risk product categories. For newly enrolled suppliers, including enrollment of new office locations, the first year of Medicare participation will involve additional administrative requirements and heightened scrutiny. Suppliers considering acquisitions, mergers, or ownership restructurings should also carefully assess whether a transaction could trigger the PPA requirements. CMS will notify affected suppliers through enrollment-related communications, including notification letters and welcome materials issued by the National Provider Enrollment (NPE) contractors.

Before the October 15, 2026 implementation date, if you determine that your company will be subject to the program, review the affected HCPCS codes, train staff on prior authorization procedures, and establish processes to ensure timely, complete submissions. Incorporating prior authorization processes into your operational workflows from the outset will help avoid delays in furnishing items and billing Medicare. Ultimately, strong documentation practices, effective records management, and ongoing compliance oversight will be critical to minimizing denials and maintaining uninterrupted access to care for Medicare beneficiaries.

For more information, visit CMS's webpage on Probationary Prior Authorizations.