CMS Expands Medicare DMEPOS Oversight: What Providers Must Know About the 2026 Master List Update

Key Takeaways

• CMS finalized updates to the DMEPOS Master List in the January 13, 2026 Federal Register.
• The changes take effect April 13, 2026.
• 18 HCPCS codes were added to the Master List.
• Eight oxygen-related codes were added to the F2F/WOPD List.
• Seven new codes were added to the Required Prior Authorization List.
• Providers must strengthen documentation and compliance workflows to avoid denials.

Healthcare organizations that proactively adapt to these requirements will be better positioned to maintain compliance, optimize reimbursement, and reduce revenue cycle risk.

Understanding the Latest CMS Changes to Face-to-Face, Prior Authorization, and Written Order Requirements

In a notice published in the January 13, 2026 Federal Register, the Centers for Medicare & Medicaid Services (CMS) finalized updates to its Master List of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) items that may be subject to heightened documentation and authorization requirements. These HCPCS Level II code updates become effective April 13, 2026.

The revised lists introduce new compliance obligations for providers and suppliers, expand oversight of high-risk items, and reinforce CMS’ continued focus on reducing improper payments, fraud, waste, and abuse within the Medicare program.

For healthcare organizations, billing teams, and DME suppliers, understanding these changes is essential to prevent claim denials, ensure documentation compliance, and maintain reimbursement integrity.

What Is the DMEPOS Master List?

CMS established the DMEPOS Master List framework in 2020 to identify items that may require additional safeguards before Medicare payment is made. The agency maintains three related oversight lists:

• Master List of Items Potentially Subject to Requirements
• Required Face-to-Face Encounter and Written Order Prior to Delivery (F2F/WOPD) List
• Required Prior Authorization List

The Master List, last updated in May 2024, currently includes 512 DMEPOS items appearing on the DMEPOS Fee Schedule that meet specific risk-based criteria.

Why CMS Uses the Master List

Items are included based on factors such as:

• High utilization or spending levels
• Historical improper payment rates
• Susceptibility to fraud or abuse
• Evidence of aberrant billing patterns
• Payment threshold criteria

The Master List itself does not automatically impose prior authorization or documentation requirements. Instead, it serves as a pool from which CMS may select items for additional review requirements in the future.

The goal is to ensure that items billed to Medicare meet medical necessity, coverage, and payment rules before reimbursement.

New HCPCS Codes Added to the Master List (Effective April 13, 2026)

CMS is adding 18 HCPCS Level II codes to the Master List. Some were included due to updated payment thresholds, while others were added because CMS identified unusual billing trends.

Key Categories of Newly Added Items

The additions span several clinical categories:

Diabetes Management

• A4238 — Continuous glucose monitor supply allowance
• E2103 — Non-adjunctive continuous glucose monitor or receiver

These additions reflect growing utilization of remote patient monitoring technologies and CMS’ interest in ensuring appropriate use.

Wound Care Supplies

• A6214 — Foam dressings
• A6233 — Hydrogel-impregnated gauze dressings

High-cost wound care products have historically shown variability in documentation and medical necessity determinations.

Compression and Vascular Support

• A6583 — Gradient compression wraps
• A6593 — Compression garment accessories

Respiratory and Airway Management Equipment

• A7025 — Chest wall oscillation system vest replacement
• E0468 — Dual-function home ventilator with cough stimulation
• E0469 — Lung expansion airway clearance device

Therapeutic and Stimulation Devices

• E0743 — External nerve stimulator for restless legs syndrome
• E0762 — Transcutaneous electrical joint stimulation device

Mobility and Orthotic Devices

• E2377 — Power wheelchair controller upgrade
• L1499 — Spinal orthosis (unspecified)
• L2999 — Lower extremity orthosis (unspecified)
• L5783 — Residual limb volume management system
• L5841 — Endoskeletal knee-shin system addition

Other Equipment

• E0691 — Ultraviolet light therapy system
• E1399 — Miscellaneous DME category

The inclusion of “not otherwise specified” codes reflects CMS’ concern about broad billing categories that may be prone to misuse.

Updates to the Required Face-to-Face Encounter and Written Order Prior to Delivery List

CMS also expanded the Required Face-to-Face Encounter and Written Order Prior to Delivery (F2F/WOPD) List, which currently contains 75 items, including 46 power mobility devices mandated by statute.

Eight New Oxygen Equipment Codes Added

CMS is adding eight HCPCS codes related to oxygen and oxygen delivery systems:

• E0424 — Stationary compressed gaseous oxygen system
• E0431 — Portable gaseous oxygen system
• E0433 — Portable liquid oxygen system (home liquefier)
• E0434 — Portable liquid oxygen system
• E0439 — Stationary liquid oxygen system
• E1390 — Oxygen concentrator (single port)
• E1391 — Oxygen concentrator (dual port)
• E1392 — Portable oxygen concentrator

What F2F/WOPD Requirements Mean

For items on this list:

• A treating practitioner must conduct a documented face-to-face encounter with the patient.
• A written order must be completed before the equipment is delivered.
• Suppliers must maintain documentation supporting medical necessity.

Failure to meet these requirements can result in claim denial regardless of medical necessity.

Required Prior Authorization List: New Additions

The Required Prior Authorization List, which currently includes 67 items, is being updated with seven additional HCPCS codes.

New Orthotic and Compression Devices Added

Orthoses

• L0651 — Lumbar-sacral orthosis
• L1844 — Custom fabricated knee orthosis (single upright)
• L1846 — Custom fabricated knee orthosis (double upright)
• L1852 — Prefabricated knee orthosis
• L1932 — Carbon fiber ankle foot orthosis

Pneumatic Compression Devices

• E0651 — Pneumatic compressor without calibrated pressure
• E0652 — Pneumatic compressor with calibrated pressure

CMS’ Comprehensive Error Rate Testing (CERT) program has consistently identified orthoses among the top DMEPOS categories associated with improper payments, which contributed to their inclusion.

How the Prior Authorization Process Works

Before furnishing items on the Required Prior Authorization List, suppliers or providers must submit a request demonstrating that the item meets Medicare requirements.

Required Documentation Includes:

• Written order or prescription
• Relevant medical records supporting medical necessity
• Supplier-produced documentation
• Evidence of compliance with coverage and coding policies

After submission, CMS or its review contractor evaluates the request and issues one of two decisions:

• Provisional Affirmation — Item meets Medicare requirements.
• Non-Affirmation — Documentation is insufficient or requirements are not met.

Prior authorization decisions help ensure coverage eligibility before claim submission, reducing post-payment audits and recoupments.

Operational and Financial Impact for Providers and Suppliers

The 2026 updates may significantly affect clinical workflows, revenue cycle operations, and compliance programs.

Potential Challenges

Healthcare organizations may experience:

• Increased documentation burden
• More complex intake and order validation processes
• Higher risk of claim denials without proper workflows
• Additional administrative coordination between clinicians and suppliers
• Longer reimbursement timelines if processes are not optimized

Compliance Opportunities

However, organizations that implement strong processes may benefit from:

• Reduced audit risk
• Fewer payment recoupments
• Improved claim accuracy
• More predictable reimbursement outcomes

Best Practices for Preparing for the 2026 Updates

To maintain compliance and reduce disruption, providers should consider:

1. Updating Billing and Coding Protocols

Ensure charge capture and coding teams recognize newly added HCPCS codes and requirements.

2. Strengthening Documentation Workflows

Implement standardized templates for face-to-face encounters and written orders.

3. Training Clinical and Administrative Staff

Educate physicians, intake teams, and DME suppliers on documentation expectations.

4. Monitoring Claim Denials

Track denial patterns related to DMEPOS items to identify compliance gaps.

5. Conducting Internal Audits

Regular chart audits can help detect deficiencies before external review.

Why These Updates Reflect a Broader CMS Strategy

The 2026 changes align with CMS’ broader policy direction emphasizing:

• Value-based care accountability
• Payment integrity initiatives
• Program integrity and fraud prevention
• Evidence-based utilization of high-cost medical equipment

By expanding oversight of high-risk categories like orthoses, respiratory equipment, and remote monitoring devices, CMS continues to prioritize appropriate utilization and cost control.

Stay Ahead of DMEPOS Compliance with Expert Support

Navigating evolving DMEPOS regulations, prior authorization requirements, and documentation standards can place significant strain on providers and suppliers. Even minor compliance gaps can lead to claim denials, delayed reimbursements, or audit exposure — particularly as CMS expands oversight of high-risk equipment categories.

Partnering with an experienced DME billing and coding team can help organizations stay compliant while maintaining operational efficiency. At Bristol, our certified DME coding specialists and revenue cycle experts help providers:

• Ensure accurate HCPCS coding and documentation compliance
• Manage prior authorization and face-to-face requirements
• Reduce denials and audit risk
• Streamline DME billing workflows
• Maximize reimbursement while meeting CMS regulations

As Medicare continues to strengthen program integrity measures, proactive compliance is no longer optional — it’s essential. With expert support, providers can confidently adapt to regulatory changes while protecting revenue and focusing on patient care.

Ready to strengthen your DME billing and compliance strategy? Connect with our experts to learn how Bristol can help.