On February 27, 2026, the Centers for Medicare & Medicaid Services (CMS) published a Notice that it is using its ACA-provided authority to impose a temporary (six-month) nationwide moratorium on the Medicare enrollment of certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) medical supply companies.
1. The Moratorium Covers Seven Specific Medical Supply Company Types
The moratorium applies to seven categories of medical supply companies seeking to newly enroll in Medicare: (1) medical supply company; (2) medical supply company with orthotics personnel; (3) medical supply company with pedorthic personnel; (4) medical supply company with prosthetics personnel; (5) medical supply company with prosthetic and orthotic personnel; (6) medical supply company with registered pharmacist; and (7) medical supply company with respiratory therapist.
2. It's a Nationwide, Six-Month Freeze Driven by Fraud Waste and Abuse Concerns
Unlike previous moratoria that targeted specific geographic regions, this action applies to the entire United States, including all states, territories, and the District of Columbia. The moratorium lasts six months but may be extended in additional six-month increments if CMS deems it necessary. The moratorium stems from the government’s longstanding and escalating concerns about fraudulent billing schemes in the DMEPOS sector. As the HHS Office of Inspector General (OIG) noted in February 2025, "[f]or over a decade, OIG has raised concerns about fraudulent practices among DME suppliers and has highlighted billions of dollars in potentially improper Medicare payments made to suppliers."
3. Medical Supply Companies Have a Specific Definition
CMS stated that a medical supply company is a business whose principal function is to furnish DMEPOS supplies directly to another party. These include supplying to one or both of the following: beneficiaries with a medical order (including by mail order) or medical providers or suppliers. CMS specifically stated that the moratorium would not apply to a grocery store, pharmacy, or inpatient or outpatient medical providers whose principal function is not the provision of DMEPOS. “It is instead, for instance, the selling of food, or toiletries, the dispensing of medicines, the direct provision of medical care (such as a hospital, HHA, physician’s office), etc. Hence, the moratorium would generally not apply to these DMEPOS suppliers.”
4. Currently Enrolled Suppliers Can Continue Operating
The moratorium only affects new enrollments; currently enrolled medical supply companies can continue billing Medicare and operating normally. However, suppliers opening new practice locations will be treated as initial enrollments and thus subject to the moratorium.
5. Certain Activities Are Exempt
The moratorium does not apply to changes in practice location (unless moving from outside to inside the moratorium area), changes in supplier information like phone numbers, or changes in ownership (except those requiring initial enrollment). Applications received before the effective date are also exempt.
6. CMS Will Closely Screen All DMEPOS Applications
CMS has warned that it will "very closely screen all DMEPOS supplier applications submitted during the moratorium" to ensure suppliers aren't medical supply companies trying to enroll under a different type. Attempts to circumvent the moratorium through false or misleading information could result in denial, a reapplication bar of up to 10 years, and referral to the OIG for potential criminal, civil, or administrative penalties.
7. States Decide About Medicaid and CHIP
While CMS has the authority to extend the moratorium to Medicaid and CHIP, it has opted to let individual states decide whether to implement similar moratoria for their programs. CMS is encouraging states to consider tailored moratoria based on their specific beneficiary populations and geographic factors, and is offering consultation to any state interested in doing so.
8. Beneficiary Access Is Expected to Remain Strong
CMS does not anticipate that the moratorium will harm beneficiary access to care. Per CMS, with over 79,000 DMEPOS suppliers currently enrolled—including more than 6,000 medical supply companies—and with pharmacies, hospitals, and other DMEPOS suppliers still able to open new locations, CMS believes the existing network can meet beneficiary needs. Additionally, the prevalence of mail-order DMEPOS services provides patients with geographic flexibility.
As DMEPOS suppliers structure deals or simply try to make changes to existing structures, it will be important to understand the consequences of needing a brand-new DMEPOS enrollment. The Notice cites several fraud and abuse issues that CMS, OIG, and others have studied or found, and it looks to be a sign that they are acutely aware of the fraud, waste, and abuse concerns within this sector.
