Medicare DMEPOS Supplier Enrollment Moratorium Ends: What Medical Groups Expanding Into O&P Need to Know

If your medical group has been considering expanding into Orthotics & Prosthetics, we have good news: The Medicare DMEPOS supplier enrollment moratorium is over.

On August 27, 2026, the six-month moratorium affecting certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) supplier enrollments officially expired.

CMS has confirmed that National Provider Enrollment Contractors are once again accepting applications for DMEPOS supplier enrollment.

For existing medical groups interested in adding O&P services, that removes a significant roadblock. But it doesn’t necessarily make entering the O&P space simple.

Medicare has spent much of 2026 increasing its oversight of DMEPOS suppliers. So, if O&P expansion is part of your medical group’s growth strategy, now is a good time to understand both the opportunity and the requirements that come with it.

Why Did Medicare Pause New DMEPOS Supplier Enrollments?

On February 27, 2026, CMS implemented a six-month nationwide enrollment moratorium targeting certain types of DMEPOS medical supply companies.

The moratorium was a program integrity measure designed to combat fraud, waste, and abuse within Medicare.

For existing enrolled suppliers, business could largely continue as usual.

For medical groups looking to enter the DMEPOS space, however, the moratorium presented a much bigger problem. Initial enrollment applications for affected supplier categories could not move forward.

That meant a medical group interested in adding certain O&P services couldn’t simply establish a new DMEPOS supplier operation and begin billing Medicare.

Can Medical Groups Expand Into O&P Again?

Yes! But Medicare enrollment is only one piece of the puzzle.

With the moratorium expired, DMEPOS supplier enrollment is open again, giving medical groups an opportunity to revisit plans for O&P expansion. That includes organizations looking to bring O&P services in-house rather than continuing to refer patients elsewhere.

But entering the O&P space involves more than simply enrolling with Medicare. Depending on your organization and the services you plan to provide, expansion may involve accreditation, supplier standards, documentation requirements, coding, prior authorization, and entirely new billing workflows.

Why Medical Groups Are Considering O&P Expansion

For the right organization, adding O&P services can be a logical extension of existing patient care.

Medical groups already treating patients with orthopedic, rehabilitation, mobility, neurological, podiatric, or other related needs may already encounter patients who require orthotic or prosthetic devices.

Bringing some of those services into the organization can create a more integrated patient experience while opening an additional service line.

But adding O&P isn’t as simple as adding another item to your list of services.

We’ve worked with medical groups that see the patient demand, recognize the opportunity, and have great practitioners, but don’t realize how different the O&P medical billing landscape is. 

DMEPOS operates within its own Medicare enrollment, coverage, documentation, coding, and reimbursement environment. And historically, as well as in 2026, CMS has made it clear that this particular healthcare environment is under close watch.

The Moratorium Is Over. CMS Scrutiny Isn’t.

The expiration of the moratorium shouldn’t be interpreted as Medicare returning to business as usual. CMS has continued increasing oversight of DMEPOS through enrollment screening, site visits, claim reviews, prior authorization, and other program integrity measures.

There’s also another important change approaching. Beginning October 15, 2026, CMS is implementing a nationwide, one-year Probationary Prior Authorization process affecting newly enrolled DMEPOS suppliers and certain suppliers undergoing changes of ownership.

For medical groups entering the DMEPOS space now, that’s particularly relevant.

Certain items furnished by affected suppliers will require prior authorization as a condition of Medicare payment. So while CMS has reopened enrollment, newly enrolled suppliers should expect additional scrutiny.

Adding O&P? Think Beyond DMEPOS Supplier Enrollment

One of the biggest mistakes a medical group can make when entering a new service line is treating enrollment as the finish line. It’s really the starting line.

Before expanding into O&P, your organization should understand how the new service will fit into your existing operations.

That includes questions like:

• Which O&P products and services will you provide?
• What enrollment, accreditation, licensing, or supplier requirements apply?
• Which HCPCS codes will you bill?
• Which items require Medicare prior authorization?
• Who will collect and verify supporting medical documentation?
• How will physician orders move through the organization?
• Who owns coding and claim submission?
• How will denials and A/R be managed?
• How will the new service line integrate with your existing revenue cycle?

These aren’t questions you want to answer after you’ve already started providing devices.

Build the Billing Workflow Before You Build the O&P Service Line

“Failing to prepare is preparing to fail” – Benjamin Franklin

Before launching an O&P service line, map the entire revenue cycle from the patient’s first interaction through final reimbursement.

Understand what documentation needs to exist before an item is delivered. Determine when prior authorization is required. Establish responsibilities between clinical and administrative teams. Make sure coding is correct. And create repeatable procedures for submitting and following up on claims.

A new service line can create additional revenue. A poorly designed service line can create additional A/R, denials, administrative work, and compliance risk.

If you’re starting this process, or just thinking about it, then Erin Cammarata’s O&P Edge article about common medical billing mistakes and how to avoid them may help you avoid likely pitfalls.

How CBS Can Help Medical Groups Expand Into O&P

If your medical group is considering adding O&P services, CBS Medical Billing & Consulting can help you understand the revenue cycle and operational requirements before, during, and after DMEPOS supplier enrollment. 

Our team has extensive experience (Erin alone has 30+ years) working with Orthotics & Prosthetics practices and navigating the unique billing requirements surrounding DMEPOS.

We can help evaluate your proposed workflow, identify billing and documentation requirements, establish repeatable processes, and determine how the new service line should integrate with your existing revenue cycle.

And once you’re operational, CBS can provide ongoing medical billing and revenue cycle support to help keep claims moving and A/R under control.

Key Takeaways for Medical Groups Considering O&P

The Medicare DMEPOS supplier enrollment moratorium officially expired on August 27, 2026.

For medical groups that delayed plans to enter the O&P space, the expiration removes an important enrollment barrier and creates an opportunity to revisit those plans.

But CMS oversight of DMEPOS remains elevated, particularly for newly enrolled suppliers.

Before expanding, medical groups should understand the enrollment, documentation, prior authorization, coding, billing, and operational requirements that will come with the new service line.

The door to O&P is open again. Before you walk through it, make sure you have a plan for what comes next.