The Centers for Medicare & Medicaid Services (CMS) announced a nationwide temporary moratorium effective February 27, 2026, restricting new Medicare enrollment for certain DMEPOS medical supply companies. This action is intended to address ongoing concerns related to fraud, waste, and abuse in the DME industry.

This FAQ outlines what the moratorium means for new and existing DME suppliers, including its impact on Medicare enrollment, CHAP accreditation, licensing, and business planning during the moratorium period.

Why did CMS impose this moratorium?

CMS said the moratorium is aimed at reducing fraud, waste, and abuse in the DMEPOS space. In the notice, CMS cited longstanding concerns from CMS, HHS-OIG, and DOJ about fraudulent billing schemes involving medical supply companies, including braces, catheters, diabetic supplies, and other high-risk supply categories. CMS also said the affected supplier specialties showed elevated rates of revocations, payment suspensions, law-enforcement referrals, and benefit integrity complaints.

Which supplier types are impacted?

The moratorium applies to new Medicare enrollments for these seven DMEPOS supplier types:

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 a registered pharmacist
7. Medical supply company with a respiratory therapist

What supplies are impacted?

The notice is focused on medical supply company supplier types, not just one single product line. CMS makes clear that a medical supply company is considered a business whose principal function is furnishing DMEPOS supplies directly to beneficiaries, providers, suppliers, or both. Examples of product areas CMS specifically discussed as program integrity concerns include:

• Orthotic braces, especially off-the-shelf braces
• Intermittent urinary catheters
• Diabetic-related supplies
• Incontinence supplies
• Other medical-supply categories are commonly furnished by mail order or direct shipment

Important nuance: the moratorium is not written as a list of HCPCS codes that are banned from being billed. It is an enrollment moratorium on certain supplier types. So the practical question is not only “what product do you sell?” but also “what type of supplier are you enrolling as, and is your principal business function a medical supply company?”

Are wheelchairs impacted?

Potentially, yes, depending on the supplier’s business model. CMS cited fraud cases involving power wheelchairs and related repairs, but the moratorium itself is not limited to wheelchairs. If a company’s principal function is that of a medical supply company and it falls into one of the seven listed supplier specialties, its new Medicare enrollment may be blocked during the moratorium.

Does this affect currently enrolled Medicare DME suppliers?

Generally, no, if the supplier is already enrolled and already has a PTAN for the location in question. CMS said the moratorium mainly affects newly enrolling suppliers and new practice locations of the covered supplier types.

Does this affect a new location for an existing supplier?

Yes, it can. For DMEPOS, each location must be separately enrolled. CMS states that a new location is treated like an initial enrollment for this purpose. So an existing supplier opening a new Medicare-enrolled location during the moratorium could be blocked if that new location falls into one of the covered medical supply company categories.

Are there any exceptions?

Yes. The moratorium generally does not apply to:

• Enrollment applications received before the effective date
• Certain changes in supplier information, such as phone number or address
• Certain ownership changes, though CMS also warns that some ownership restructurings can still trigger a new-enrollment requirement

CMS also said it will closely review applications to make sure suppliers are not trying to avoid the moratorium by selecting an inaccurate supplier type.

If we apply during the moratorium, will Medicare enrollment be delayed?

For affected supplier types, it is more than just a routine delay. In most cases, new Medicare enrollment will be denied or held out of reach for the duration of the moratorium, unless the application was received before the effective date or the supplier is outside the moratorium’s scope. Practically, that means the business may have to wait until the moratorium is lifted or expires before it can obtain Medicare billing privileges for that location/type.

What is the business impact of the enrollment delay?

For affected new DME suppliers, the business impact can be significant:

• No Medicare billing until enrollment becomes possible
• Delayed revenue and slower payer diversification
• Potential cash-flow strain
• Delayed ability to contract with referral sources that expect Medicare participation
• Operational decisions about whether to pursue licensure, accreditation, staffing, and inventory now or wait
• Added uncertainty for launches, expansions, and investor planning

For businesses building around Medicare as a primary payer, this may delay go-live timelines by at least the moratorium period, and longer if CMS extends it.

Does the moratorium stop us from becoming a DME company altogether?

No. It does not prohibit you from forming the business, obtaining state licenses, pursuing accreditation, or serving non-Medicare patients if otherwise legally allowed. What it blocks is, new Medicare enrollment for the covered supplier categories during the moratorium period.

What is the impact on state DME licensing?

The moratorium does not automatically eliminate or suspend state licensing requirements. If your state requires DME licensure or a medical equipment permit, those rules generally still apply. State licensure can still matter for:

• Operating legally in the state
• Contracting with commercial payers
• Preparing for future Medicare enrollment
• Meeting accreditation prerequisites

In other words, state licensure and Medicare enrollment are separate issues. A supplier may still need a state license even if it cannot enroll in Medicare right now.

What is the impact on CHAP accreditation?

The moratorium does not automatically bar a company from pursuing CHAP accreditation. However, accreditation does not override the Medicare moratorium. Some of the practical impact is:

• You may still pursue accreditation for business-readiness or non-Medicare payer purposes
• Accreditation alone will not get you Medicare billing privileges during the moratorium
• Businesses should weigh the cost and timing carefully if Medicare enrollment is the main reason they were seeking accreditation

For some suppliers, it may still make sense to proceed with CHAP now so they are operationally ready when Medicare reopens. For others, it may make more sense to delay depending on cash flow, target payer mix, and launch timing.

Should a supplier still pursue CHAP accreditation during the moratorium?

That depends on the business plan. It may still make sense if:

• You plan to pursue private insurance contracts that require accreditation
• You want to be survey-ready and launch quickly once Medicare reopens
• You are building a non-Medicare book of business first
• You need accreditation for broader credibility or operational infrastructure

It may make less sense if:

• Your business model depends almost entirely on near-term Medicare billing
• The accreditation cost creates avoidable financial pressure
• You would have to renew or repeat major readiness work before enrollment opens

Does the moratorium affect private insurance enrollment?

Not automatically. The moratorium is a Medicare enrollment action, not a blanket ban on commercial payer enrollment. But there can be an indirect impact:

• Some commercial payers may still credential or contract with you if you meet their requirements
• Some may require state licensure, accreditation, or proof of operational readiness
• Some payers may prefer or require Medicare enrollment in certain circumstances, or use Medicare participation as a credibility signal
• Timelines may still be longer if your overall business launch is delayed

So private insurance enrollment is not necessarily blocked, but it may be affected by your readiness, accreditation status, and payer-specific rules.

Does this moratorium apply to Medicaid and CHIP?

Not automatically nationwide in the same way. CMS said that, for now, it is leaving the decision to each state to determine whether a DME moratorium is appropriate for that state’s Medicaid or CHIP program. So, suppliers should check state-level Medicaid guidance separately.

How long does the moratorium last?

The notice says the moratorium lasts 6 months from the effective date, which is February 27, 2026. That means the initial period would run to about August 27, 2026, unless CMS lifts it earlier or extends it.

Could the moratorium open later in 2026?

Yes, that is possible. Two ways could happen:

• CMS could let the 6-month moratorium expire at the end of the period
• CMS could lift it earlier if it determines the circumstances have changed or safeguards are sufficient

But there is also a real possibility that CMS could extend it in another 6-month increment. Suppliers should plan for uncertainty and not assume it will automatically reopen in late summer 2026.

If it reopens later in the year, what happens next?

If CMS lifts the moratorium, affected suppliers can resume pursuing enrollment. CMS also notes that suppliers applying within 6 months after a moratorium is lifted may be placed in the high screening level, which can mean closer scrutiny and additional enrollment burden.

Should suppliers wait or prepare now?

That depends on payer strategy and capital. A practical middle-ground approach is often:

• Continue with state licensing
• Continue building policies, procedures, and documentation
• Decide whether accreditation now is worth the cost based on the commercial payer strategy
• Avoid assuming near-term Medicare revenue
• Monitor CMS closely for extension or lifting announcements

Can an affected supplier appeal?

The scope of any appeal is very limited. CMS states there is no judicial review of the decision to impose the moratorium itself. An administrative appeal would generally be limited to whether the moratorium actually applies to the supplier.

Will application fees be lost?

CMS states that if an application is denied because of the moratorium, any required application fee will be refunded

Practical takeaway for DME suppliers

For new medical supply company DME suppliers, the moratorium is mainly a Medicare enrollment freeze, not a full business shutdown. The biggest impacts are:

• delayed Medicare entry,
• delayed revenue,
• a harder decision on whether to spend money now on licensure and CHAP accreditation, and
• The need to decide whether to build around private pay/commercial plans first while watching for CMS to reopen enrollment later in 2026.

Conclusion

The Medicare moratorium creates a temporary but important barrier for new DME medical supply companies that plan to enroll in Medicare. While it does not stop businesses from forming, obtaining state licensure, pursuing accreditation, or serving non-Medicare patients, it does delay Medicare enrollment for the affected supplier categories and may significantly impact launch timelines, revenue planning, and payer strategy.

TriumpHealth team can help DME suppliers navigate this period strategically by evaluating whether to move forward now, pause certain investments, or prepare for fast action once Medicare enrollment reopens. The key is not to treat the moratorium as a full stop, but as a period for careful planning, compliance readiness, and smarter market positioning.

To learn more or schedule a consultation, please call us at (888) 747-3836  or email us at [email protected].