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Analysis

CMS Adds Certain Surgical Dressings to DMEPOS Master List: What Providers Need to Know

The Centers for Medicare & Medicaid Services (CMS) has added two surgical dressing HCPCS codes to its DMEPOS Master List of items potentially subject to conditions of payment, effective October 28, 2026. Although the change does not impose prior authorization requirements at this time, the affected items could be considered for inclusion on CMS's Required Prior Authorization List in the future.

Key Takeaways

  • Two surgical dressing HCPCS codes added: CMS has added A6022 (collagen dressing) and A6107 (alginate or other fiber gelling dressing) to the DMEPOS Master List, effective October 28, 2026.
  • No immediate prior authorization requirement: Placement on the Master List alone does not change billing or documentation requirements or require prior authorization unless an item is later added to the Required Prior Authorization List.
  • Potential future reimbursement implications: CMS identifies Master List items as having potential concerns related to fraud or unnecessary utilization, making them eligible for future consideration for prior authorization. Currently, only 82 of the 550 items on the Master List also appear on the Required Prior Authorization List.

The Centers for Medicare and Medicaid Services (CMS) have added certain surgical dressings to their "Master List of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Items Potentially Subject to Conditions of Payment,”1 effective October 28, 2026.

Wound care professionals and stakeholders should note that the surgical dressings added to the Master List were:

  • A6022 - Collagen dressing, sterile, size more than 16 sq. in. But less than or equal to 48 sq. in., each 2
  • A6107 - Alginate or other fiber gelling dressing, wound cover, sterile, pad size more than 16 sq. in. But less than or equal to 48 sq. in., each dressing 2

Despite stakeholder efforts to resist prior authorization expansion within the Medicare program, CMS continues to employ artificial intelligence and machine learning to broaden prior authorization requirements. CMS maintains these two lists related to prior authorization within their DME program1:

  • Master List of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Items Potentially Subject to Conditions of Payment
  • Required Prior Authorization List

Medicare claims that items on the “Master List” are "a source of potential fraud or unnecessary utilization.” Items on this Master List are candidates to be added to the CMS "Required Prior Authorization List,” but are not automatically added to the prior authorization requirement. An item has to be on the Master List first in order for it to be selected for the Required Prior Authorization List. If an item is only on the Master List and not on the Required Prior Authorization List, providers do not have to do anything differently when supplying that item. There is no prior authorization required for items that are only on the Master List.

Durable medical equipment (DME) suppliers can handle items that are only on the Master List exactly how they handle items that are not on the Master List. However, suppliers of these items on the Master List should be aware that CMS expresses the concerns listed above about fraud and utilization associated with their use. As always, compliance with third party payer compliance and documentation guidelines is essential.

With the items represented by A6022 and A6107 added to the Master List, CMS is announcing their contention that these items are "a source of potential fraud or unnecessary utilization” and these items could eventually be added to the Required Prior Authorization List. There is no way to know for certain which items on the Master List will be added to the Required Prior Authorization List. At the moment, there are 550 items on the Master List and only 82 of those items are also on the Required Prior Authorization List.

References

    1. Centers for Medicare and Medicaid Services. Master List of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Items Potentially Subject to Conditions of Payment. Accessed July 31, 2026. https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/medical-review-and-education/master-list-dmepos-items-potentially-subject-conditions-payment
    2. Centers for Medicare and Medicaid Services. CMS listing of CPT/HCPCS Codes. Accessed July 31, 2026. https://www.cms.gov/medicare/regulations-guidance/physician-self-referral/list-cpt-hcpcs-codes
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