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CMS WatchSeptember 15, 2026·5 min read

CMS DMEPOS probationary prior auth starts October 15 for new and CHOW suppliers

Starting October 15, 2026, CMS requires a one-year probationary prior authorization (PPA) for certain DMEPOS items billed by newly enrolled suppliers and suppliers undergoing certain changes of ownership. Prior authorization is a condition of payment for the HCPCS on the Probationary Prior Authorization List.

DMEPOSPrior AuthorizationPPAMLN ConnectsCMS Watch
HCC Buddy

By the HCC Buddy Coding Team

Published September 15, 2026

A DME billing desk shows an orthosis order form and a prior authorization checklist next to a closed laptop.
CMS probationary prior authorization for certain DMEPOS items begins October 15, 2026 for newly enrolled and CHOW suppliers.Image: HCC Buddy

Key Takeaways

  • Starting October 15, 2026, CMS requires probationary prior authorization for certain DMEPOS items billed by newly enrolled suppliers and suppliers undergoing certain changes of ownership.
  • The program is a nationwide one-year probationary period under Section 1866(j)(3) of the Social Security Act and 42 CFR 424.527. The period begins when the supplier submits their first bill for an item on the Probationary Prior Authorization List.
  • Prior authorization is a condition of payment for HCPCS on the Probationary Prior Authorization List for dates of service on or after October 15, 2026.
  • The September 1, 2026 PPA PDF lists 40 HCPCS codes (osteogenesis stimulators E0747 and E0748 plus spinal and extremity orthoses), all effective 10/15/2026.
  • PPA does not replace the existing required Prior Authorization Process for Certain DMEPOS Items. Suppliers in PPA must still meet those existing PA requirements where they apply.

On September 10, 2026, CMS MLN Connects told suppliers that DMEPOS Probationary Prior Authorization starts October 15. The CMS PPA process page (last Update 9/1/2026) already set the operational rules and points to the Probationary Prior Authorization List PDF.

EFFECTIVE DATE: October 15, 2026 for dates of service on or after that day for items on the Probationary Prior Authorization List.

This is a supplier-enrollment and prior-auth stack story for the CMS Watch desk. It is not a rewrite of the live October 2026 DMEPOS required PA and face-to-face list (effective October 28). Keep both lists next to each other on the desk.

What starts October 15

CMS will:

  • Implement a nationwide 1-year probationary prior authorization (PPA) process for newly enrolled DMEPOS suppliers and suppliers undergoing a change of ownership
  • Require prior authorization as a condition of payment for certain DMEPOS items on the Probationary Prior Authorization List (PDF) with dates of service on or after October 15, 2026

Authority cited on the PPA page is Section 1866(j)(3) of the Social Security Act and 42 CFR 424.527. The one-year probationary period begins when a supplier submits their first bill for one of the DMEPOS items on that Probationary Prior Authorization List.

Who is in scope

PPA applies to:

  • Newly enrolled DMEPOS suppliers
  • Suppliers undergoing certain changes of ownership

effective on or after October 15, 2026.

MLN Connects also reminds new and change-of-ownership suppliers that they remain subject to regular program oversight initiatives, including required prior authorization, face-to-face encounter, and written order prior to delivery requirements that already sit on the DMEPOS stack.

CMS warns on the PPA page that newly enrolled DMEPOS suppliers must also participate in the wider required prior authorization process for certain high-risk DMEPOS items. PPA does not replace that existing process.

The Probationary Prior Authorization List

The September 1, 2026 PDF lists 40 HCPCS codes, all with effective date 10/15/2026. The list is mostly spinal and extremity orthoses, plus two osteogenesis stimulators:

HCPCSShort description from the PPA list
E0747Osteogenesis stimulator, electrical, non-invasive, other than spinal
E0748Osteogenesis stimulator, electrical, non-invasive, spinal
L0626Lumbar orthosis, sagittal control, rigid posterior panel(s), custom fitted
L0627Lumbar orthosis, sagittal control, rigid anterior and posterior panels, custom fitted
L0641Lumbar orthosis, sagittal control, rigid posterior panel(s), off-the-shelf
L0642Lumbar orthosis, sagittal control, rigid anterior and posterior panels, off-the-shelf
L4360Walking boot, pneumatic and/or vacuum, with or without joints, with or without interface material, custom fitted
L4361Walking boot, pneumatic and/or vacuum, with or without joints, with or without interface material, off-the-shelf

That table is a sample only. Confirm the full 40-code set in the official PDF before you change a charge master or PA workflow. CMS says it may update the list if new vulnerabilities arise and will post changes on the PPA webpage.

Use the encoder or code book when you need the full HCPCS descriptor for an orthosis or stimulator on a claim.

How PPA relates to the existing DMEPOS PA program

The PPA process follows the same submission and review steps as the established Prior Authorization Process for Certain DMEPOS Items. CMS points suppliers to the current DMEPOS PA Operational Guide (PDF).

Two desks, two lists:

ProgramWhoCondition of payment listEffective for this story
Probationary Prior Authorization (PPA)Newly enrolled and certain CHOW suppliersPPA code list PDF (40 HCPCS)October 15, 2026
Required Prior Authorization (existing)Suppliers billing listed high-risk DMEPOS itemsRequired PA list on the DMEPOS PA webpageOngoing; see also the live Oct 28 PA / F2F list story

Suppliers in PPA must still meet the existing required prior authorization rules for any applicable DMEPOS items on that separate list.

What billers and DME desks should do now

  • Pull the September 1, 2026 PPA PDF and mark every HCPCS you stock or bill.
  • For any newly enrolled or CHOW supplier NPI, confirm whether PPA starts on the first claim for a listed item on or after October 15, 2026.
  • Keep required PA, face-to-face encounter, and written-order-prior-to-delivery checklists in the same workflow, not as a substitute for PPA.
  • Do not confuse October 15 PPA with the October 28 required PA and face-to-face list updates already covered on CMS Watch.
  • When a claim denies for missing PA on a listed orthosis or stimulator, re-check which list and which enrollment status applied on the date of service.

This page stays on the probationary process CMS printed in MLN Connects (September 10, 2026) and on the PPA webpage (Update 9/1/2026). It is not a CMS-HCC, V28, or RADV documentation change.

What coders should do now

  1. 1Download the September 1, 2026 Probationary Prior Authorization List PDF and flag every HCPCS your DME or orthotics desk bills.
  2. 2For newly enrolled or CHOW supplier NPIs, treat the first claim for a listed item on or after October 15, 2026 as the start of the one-year PPA clock.
  3. 3Keep required prior authorization, face-to-face encounter, and written-order-prior-to-delivery checks in the same intake path. PPA does not waive them.
  4. 4Separate October 15 PPA work from the October 28 required PA and face-to-face list updates already covered on the live CMS Watch DMEPOS PA list article.
  5. 5When a remittance cites missing prior auth on a listed orthosis or stimulator, confirm which list and which enrollment status applied on the date of service before you rebill.

Frequently Asked Questions

When does DMEPOS probationary prior authorization start?

CMS MLN Connects (September 10, 2026) and the PPA webpage say the process starts October 15, 2026. Prior authorization is a condition of payment for listed items with dates of service on or after that date.

Which suppliers fall under PPA?

Newly enrolled DMEPOS suppliers and suppliers undergoing certain changes of ownership, effective on or after October 15, 2026. The one-year probationary period begins when the supplier submits their first bill for an item on the Probationary Prior Authorization List.

How many HCPCS are on the Probationary Prior Authorization List?

The September 1, 2026 PDF lists 40 HCPCS codes, all with effective date 10/15/2026. Confirm the current PDF before you change a workflow, because CMS may update the list.

Does PPA replace the existing DMEPOS required prior authorization program?

No. CMS says the Probationary Prior Authorization Process does not replace the existing Prior Authorization Process for Certain DMEPOS Items. Suppliers in PPA must continue to comply with existing prior authorization requirements for applicable items.

Is this the same as the October 28 DMEPOS PA and face-to-face list update?

No. October 15 PPA is a one-year probationary process for newly enrolled and certain CHOW suppliers. The live CMS Watch article on the October 28 required PA and face-to-face lists covers a separate list and effective date.

Related topics:DMEPOSPrior AuthorizationPPAMLN ConnectsCMS Watch
HCC Buddy

HCC Buddy Coding Team

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