CMS updates the Medicare prior authorization required list
CMS added seven items to the Medicare Required Prior Authorization List for DMEPOS in a notice dated January 13, 2026, effective April 13, 2026, and eight more in a notice dated July 30, 2026, effective October 28, 2026. The list covers durable medical equipment, prosthetics, orthotics and supplies, not hospital or physician services.
Written by Salman Saeed, CEO and Co-Founder · Reviewed by a Certified Medical Coder · 
In short: two Federal Register notices (91 FR 1250 and 91 FR 47972) put 15 more HCPCS codes, mainly orthoses, wheelchairs, pressure-reducing beds and pneumatic compression pumps, under Medicare prior authorization as a condition of payment. Practices that order these items must supply the written order and records that the supplier's request needs.
What did CMS publish, and what does the list cover?
CMS published two notices that update three lists for DMEPOS: the Master List, the Required Face-to-Face Encounter and Written Order Prior to Delivery List, and the Required Prior Authorization List. Only items that are chosen and announced in a Federal Register notice carry those conditions of payment.
| Notice | Date and citation | Effective | Added to Required Prior Authorization List |
|---|---|---|---|
| CMS-6097-N, RIN 0938-ZB98 | January 13, 2026, 91 FR 1250 (document 2026-00487) | April 13, 2026 | 7 HCPCS codes, bringing the list from 67 to 74 items |
| CMS-6109-N, RIN 0938-ZC04 | July 30, 2026, 91 FR 47972 (document 2026-15446) | October 28, 2026, with phases for upper limb orthoses | 8 HCPCS codes, added to the 74 already on the list |
Which items were added?
| Notice | HCPCS codes | Items |
|---|---|---|
| January 2026 | L0651, L1844, L1846, L1852, L1932 | Five orthoses: lumbar-sacral, custom and off-the-shelf knee, and ankle foot |
| January 2026 | E0651, E0652 | Two segmental pneumatic compression pumps for home use |
| July 2026 | E0194 | Air fluidized bed |
| July 2026 | K0005 | Ultralightweight manual wheelchair |
| July 2026 | L1833 | Prefabricated off-the-shelf knee orthosis |
| July 2026 | L0456, L0457, L0486 | Thoracic-lumbar-sacral orthoses |
| July 2026 | L3761, L3916 | Two upper limb orthoses (elbow, wrist hand), phased by state |
The July notice phases the two upper limb orthoses by state. Phase one starts October 28, 2026 in New York, Michigan, Florida and California. Phase two starts January 26, 2027 and adds Pennsylvania, Massachusetts, Ohio, Illinois, Texas, Georgia, Arizona and Oregon. Phase three starts April 26, 2027 for all other states and territories. The other six July codes start October 28, 2026 nationwide.
CMS also added codes to the Master List (18 in January, 20 in July) and to the face-to-face and written order list (8 oxygen codes in January, 22 codes in July). Those lists carry order rules rather than prior authorization.
Who does this affect?
DMEPOS suppliers carry the prior authorization request, but the ordering practitioner supplies what the request needs. Orthopedic practices ordering braces and any group writing equipment orders are in scope. This list applies to Original Medicare DMEPOS, not to commercial plans or the hospital outpatient list.
CMS says a requester must submit a request before providing the item and before submitting the claim. The request must include the written order or prescription, relevant medical record information and supplier documentation. A missing authorization is what CO-197 reports.
What should you do now?
- Compare the codes you order against the table above, especially orthoses and manual wheelchairs.
- Tell your DME suppliers which of your patients need the July items, because the start date is October 28, 2026.
- Check that each order is signed and dated before delivery, and that the chart shows the clinical need the item is billed for.
- For upper limb orthoses, note the patient's state against the three phases.
- Track provisional affirmations and non-affirmations, and send non-affirmed requests back for added records. The denial management playbook covers the follow-up.
What is still open?
CMS says it will issue item-specific guidance and final decision timelines in sub-regulatory communications, and that it can suspend the program if it is creating barriers to care. Phase two and three dates for upper limb orthoses are still ahead. Medicare Advantage decision times are different, as set out in what prior authorization is in billing. The Medicare payer guide and LCDs and NCDs cover coverage rules.
Our prior authorization service tracks the required documents for each payer. Book a call to review your equipment orders.
- Medicare Program; Updates to the Master List of Items Potentially Subject to Face to Face Encounter and Written Order Prior to Delivery and/or Prior Authorization Requirements (CMS-6097-N), 91 FR 1250 · Federal Register
- Medicare Program; Updates to the Master List of Items Potentially Subject to Face-to-Face Encounter and Written Order Prior to Delivery and/or Prior Authorization Requirements (CMS-6109-N), 91 FR 47972 · Federal Register
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Common questions
Straight answers from the team that does the work.
Ask a billing lead directly. A 20-minute call, Monday to Friday, 9am to 5pm Eastern.
01What is the Medicare Required Prior Authorization List?
It is the list of DMEPOS items that need Medicare prior authorization as a condition of payment. CMS selects items from its Master List and announces them in the Federal Register with at least 60 days' notice. A supplier or requester must submit a request before providing the item and filing the claim.
02When do the July 2026 Medicare prior authorization additions take effect?
The eight items in the July 30, 2026 notice (91 FR 47972) take effect October 28, 2026. Two upper limb orthoses, L3761 and L3916, start that day in New York, Michigan, Florida and California only, then reach more states on January 26, 2027 and the rest on April 26, 2027.
03Does this change prior authorization for hospital outpatient services?
No. These notices update the DMEPOS lists under 42 CFR 414.234 and 410.38. Hospital outpatient department prior authorization has its own list, and Medicare Advantage plans follow their own decision rules. Check the supplier's equipment codes against the table, not your procedure codes.
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