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CMS Probationary Prior Authorization Requirements for Certain DMEPOS Suppliers Begin October 15

Key Takeaways 

  • Beginning October 15, 2026, CMS will require probationary prior authorization for 40 DMEPOS items billed by newly enrolled suppliers and suppliers undergoing certain ownership changes.  

  • The affected items include pneumatic or vacuum walking boots billed under HCPCS codes L4360 and L4361, which may be used when caring for plantar foot ulcers.  

  • The 1-year probationary period begins with a supplier’s first claim for an item on the CMS list and does not replace other applicable DMEPOS prior authorization requirements. 

Beginning October 15, 2026, the Centers for Medicare & Medicaid Services (CMS) will require probationary prior authorization for selected durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) billed by newly enrolled suppliers and suppliers undergoing certain changes of ownership. 

The requirement applies to 40 Healthcare Common Procedure Coding System (HCPCS) codes identified by CMS. Among the listed items are pneumatic or vacuum walking boots billed under HCPCS codes L4360 and L4361, which may be used as part of offloading strategies for patients with plantar foot ulcers. 

Under the new process, affected suppliers must obtain prior authorization to confirm that an item meets applicable Medicare coverage, payment, and coding requirements. The one-year probationary period begins when a supplier submits its first claim for an item on the list. 

CMS noted that the probationary process does not replace its existing prior authorization program for certain DMEPOS items. Suppliers must continue to comply with any other applicable prior authorization requirements. CMS may also revise the probationary list if additional vulnerabilities are identified. 

Clinicians and wound care organizations that dispense or coordinate access to pneumatic walking boots should determine whether their DMEPOS suppliers are subject to the new requirement and consider whether prior authorization could affect product delivery. 

View the CMS program overview and the full list of affected HCPCS codes

Reference 

  1. Centers for Medicare & Medicaid Services. Probationary prior authorization process for newly enrolled suppliers of certain durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) items. Updated September 1, 2026. Accessed September 11, 2026. https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/prior-authorization-pre-claim-review-initiatives/probationary-prior-authorization-process-newly-enrolled-suppliers-certain-durable-medical-equipment 

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