Medicare Freezes New DMEPOS Enrollments For O&P Suppliers With CMS-6099-N
You may have heard that Medicare has stopped issuing supplier numbers for DMEPOS suppliers entirely…Well, not quite. Supplier numbers are not outright halted, however, CMS-6099-N issued a targeted six-month moratorium on new DMEPOS suppliers in specific “medical supply company” categories, including those connected to O&P services. Existing suppliers can continue operating without issue, but new enrollments, locations, and certain ownership changes are temporarily paused.
For many O&P organizations, the key questions are simple:
- What does this mean for current operations?
- How will this affect our expansion plans?
- Can new suppliers enter the market this year?
This blog will help you better understand the Medicare DMEPOS enrollment moratorium and know how it affects you throughout 2026. Of course, changes to these CMS policies happen frequently, so be sure to check our blog for updates and further insights.
What Is CMS-6099-N?
In short: CMS-6099-N is the Federal Register notice announcing a nationwide Medicare DMEPOS enrollment moratorium for certain supplier types.
In practical terms: it’s an announcement of a temporary freeze on new enrollments for seven specific DMEPOS (Durable Medical Equipment, Prosthetics, Orthotics, and Supplies) specialty suppliers operating under particular “medical supply company” classifications.
The policy took effect 2/27/2026 and is scheduled to be in place for 6 months (ending 8/27/2026); though CMS explicitly stated that it may be extended in additional six-month increments if it’s determined that the risks prompting the policy remain.
Key insight: Not all Medicare supplier activity is halted! The Medicare DMEPOS enrollment moratorium exclusively applies to specific enrollment scenarios, like:
- New organizations attempting to enroll under the designated “medical supply company” classifications
- New practice locations which require its own unique Medicare enrollment and PTAN supplier number
- Certain ownership changes that require a new PTAN.
Existing suppliers who are already enrolled in Medicare can continue business as usual. However, those with expansion plans, acquisition ideas, or new supplier enrollments should carefully review how the CMS-6099-N Medicare DMEPOS enrollment moratorium applies.
Why Did Medicare Freeze New DMEPOS Supplier Enrollments In 2026?
CMS has a long history with DMEPOS specific program integrity and fraud prevention efforts [Last year, we wrote a blog about the DOJ False Claims Act (FCA Enformement) ramp up, if you’re interested in more historical context]. Medicare uses moratoria like CMS-6099-N when the agency identifies supplier categories (like DME supplies) or geographic areas (like Florida) that have elevated risks of fraud, waste, or abuse.
Recently, CMS determined that additional safeguards were needed before approving new enrollments within the seven designated “medical supply company” categories. This allows them to temporarily pause new supplier growth while maintaining normal operations for providers already enrolled with Medicare. While this policy may be disruptive for individuals and organizations who want to start new ventures or expand on their success, it’s an attempt to protect Medicare program integrity.
Which Supplier Types Are Impacted?
CMS-6099-N, the Medicare DMEPOS enrollment moratorium focuses on a group of classifications that fall under the broader “medical supply company” supplier type.
The Seven specialty variations included in the policy are as follows:
- Medical supply companies
- Medical supply companies with orthotics personnel
- Medical supply companies with pedorthic personnel
- Medical supply companies with prosthetic personnel
- Medical supply companies with prosthetic and orthotic personnel
- Medical supply companies with registered pharmacist
- Medical supply companies with respiratory therapist
As such, the policy has raised particular concern within the O&P community.
How CMS-6099-N Affects Orthotics & Prosthetics Providers
For most O&P organizations, there may be no noticeable operational impact – existing suppliers who are already enrolled in Medicare should continue operating normally.
However, there are two primary scenarios that are seriously affected by CMS-6099-N:
- New O&P suppliers attempting to enroll in Medicare under the specified classifications
- Existing suppliers planning to expand through new locations or new business entities.
In summary: everyday operations at your O&P practice are virtually unaffected; but expansion plans for 2026 should probably be delayed. If you’re dead set on expansion this year, the next section is for you.
Can A DMEPOS Supplier Open New Locations In 2026?
Well – maybe. But it won’t be easy.
Under Medicare enrollment rules, each practice location requires its own unique PTAN. CMS-6099-N policy restricts new enrollments, effectively blocking organizations from opening new branch locations during the moratorium period (2/27/26-8/27/26, at time of writing).
So, unless your enrollment application was submitted before February 27, 2026, your expansion efforts are offline for the foreseeable future.
But, there are some important clarifications we want to note here:
First, administrative updates, like an address or phone number change, don’t apply. These changes do not require you to get a new PTAN, you’re just adjusting the entity with your existing one.
Second, If you are a new practice owner purchasing an existing practice, then you are in the clear. The PTAN number is not changing, it is just transferring ownership. This clarification is essential to share with new and aspiring practice owners, because they especially might not have the experience to be able to parse through the new Medicare DMEPOS enrollment moratorium themselves.
Third, practices selling partial ownership interest to a shareholder are free to proceed, as the PTAN is not changing.
What Should Suppliers Planning New Enrollment in 2026 Do?
If you’re planning new enrollment in 2026, we have good news and bad.
The bad news is: for organizations planning expansion this year, the most practical advice we have is simply to wait out the moratorium period. CMS has clarified that any attempts to circumvent the moratorium through creative classification changes may yield strong enforcement action.
The good news is: this year is an excellent opportunity to optimize your current operations! Rather than focus on expansion, O&P practices will benefit most this year from improving billing processes, strengthening internal compliance systems, developing more effective SOPs for clinical documentation, and similar activities.
Delay doesn’t have to mean devastation. In fact, your practice will be better fortified for future growth once you’ve optimized your administrative and billing systems. At CBS Medical Billing And Consulting, we help O&P and other medical practices thrive through clean claims, better RCM, and other administrative, billing, and consulting services. With over 15 years of experience as a company, and over one-hundred years of cumulative experience with our personnel, we’ve helped medical practices collect over $200 million dollars in revenues.
What This Means For The O&P Industry
For our friends in O&P, CMS-6099-N policy may serve as a signal of continued regulatory scrutiny. Organizations operating under the “Medical Supply Company” classification must be aware of this policy, and any potential adjustments to the policies timeline.
Even if you aren’t exactly planning to expand your practice any time soon, the regulatory environment is tense and tightening everyday. One of the ways CBS best assists our customers is by serving as both herald and translator of these Medicare updates – we don’t just tell you what’s happening, we help you follow the new guidelines and ensure your practice remains compliant.
For O&P practices considering acquisition, partnership, and geographic growth – you guys may want to take additional time to fortify your expansion plans. Invest serious effort in evaluating Medicare’s enrollment requirements and keep an eye out for additional regulatory changes throughout your timeline.
At the same time, remember that the CMS-6099-N Medicare DMEPOS enrollment moratorium does not alter day-to-day operations for existing O&P providers. So, you can continue serving patients without needed adjustment or interruption.
CMS-6099-N Key Takeaways
The most important points for DMEPOS providers to understand are:
- Existing suppliers can continue operating normally
- The moratorium primarily affects new suppliers and expansion plans
- New practice locations and some ownership changes may require delays
- The policy is currently scheduled for six months but could be extended
Final Thoughts
The rumor mill is a funny thing. When a notice like CMS-6099-N appears, it’s easy for phrases like “Medicare has stopped issuing supplier numbers” to spread. In reality, the scope is much more limited.
The O&P industry is a tight knit community – with gratitude, the CBS Medical Billing team has been fortunate to serve it for 15+ years now. With so much experience in this field, we can say with certainty that this Medicare DMEPOS enrollment moratorium is a big deal for O&P.
Though it’s essential to be aware of this major change, it’s just as important to slow down and carefully process the new information. CMS-6099-N is a highly targeted, temporary pause – not a system shutdown. Existing suppliers can continue operating as usual. New enrollments, locations, and some expansions may have to adjust timelines.
Your best bet in 2026? Look inward, not outward. This is a great year for strengthening your current operations. CBS Medical Billing helps practices optimize administrative, billing, and clinical practices; if you’d like an expert look into any of these aspects of your practice, we’d love to connect with you.
FAQs
1. What is the Medicare DMEPOS enrollment moratorium (CMS-6099-N)?
Medicare DMEPOS enrollment moratorium (CMS-6099-N) is a temporary pause on new medicare enrollments for seven specific “medical supply company” supplier types. The policy started 2/27/26, and is scheduled to last six months but may be extended if CMS determines it necessary.
2. Does CMS-6099-N stop all Medicare supplier enrollments?
CMS-6099-N does not stop all Medicare supplier enrollments, it only applies to specific DMEPOS (durable medical equipment, prosthetics, orthotics, and supplies) classifications. Some enrollment activities, like updating an existing address or a previously submitted application, can still proceed.
3. Does the DMEPOS enrollment moratorium (CMS-6099-N) affect orthotics and prosthetics providers?
Yes, CMS-6099-N specifies that “medical supply companies with orthotic and prosthetic personnel” are among the affected classifications. New O&P suppliers and existing suppliers seeking to expand operations are directly impacted by the policy. However, existing O&P providers already enrolled in Medicare should not have day-to-day operations affected.
4. What should suppliers do if they plan to enroll in Medicare in 2026?
First, confirm whether your classification falls under the Medicare DMEPOS enrollment moratorium. Then, ensure your application was submitted before 2/27/26. If you have yet to submit an application for a medical supply company in the affected classifications, then you must wait until the moratorium period ends to enroll for a new PTAN.
