CMS Updates Prior Authorization List
On January 13, 2026, CMS announced several updates to the Master List, Required Face-to-Face and WOPD List, and Required Prior Authorization List in the Federal Register. This article will summarize the changes specifically related to orthotic and prosthetic devices, effective April 13, 2026.
What You Need to Know
The CMS "Master List" includes a list of DMEPOS items that are potentially subject to prior authorization and/or face-to-face and WOPD requirements. There are specific criteria that must be met for a code to be included on this list, all of which relate to potential vulnerabilities to the Medicare Trust Fund (i.e., high rate of fraud, high improper payment rate, large increase in payments, etc.). This list is periodically updated, and codes can either be added or removed based on the established criteria. Last month, CMS announced the addition of 18 DMEPOS HCPCS codes to the Master List, including 2 orthotic codes (L1499 and L2999) and 2 prosthetic codes (L5783 and L5841). However, just because a HCPCS code is on the Master List does not mean that it requires a prior authorization or a face-to-face encounter with WOPD. These two requirements are established by their own, separate lists that include a subset of the codes on the Master List. Effective April 13, 2026, CMS added 8 oxygen “E codes” to the Required Face-to-Face and WOPD List, along with 2 pneumatic compression device “E codes” and 5 orthotic “L codes” to the Required Prior Authorization List.
Orthotic Codes Added to Prior Authorization List, effective April 13, 2026:
- LSOs - L0651
- Knee Orthoses - L1844, L1846, and L1852
- AFOs - L1932
What This Means for You
It is important to prepare for the prior authorization changes summarized above. Starting April 13, 2026, 5 additional orthotic codes will require prior authorization from Medicare (this is in addition to the 10 orthotic codes that require prior authorization today). The DME MACs will begin accepting prior authorization requests for these new codes starting March 30, 2026. Along with educating your staff, it may be helpful to update your EMR system to flag these new requirements, so they are not missed when submitting a claim for DOS on or after April 13. You may also want to consider new office protocols and workflows for these specific orthoses to make sure that the appropriate documents are requested and received before delivery. For more information on these changes, visit the CMS website for Prior Authorizations.