DMEPOS Enrollment Moratorium Lifted: What Suppliers Need to Do Now

What Does the DMEPOS Enrollment Moratorium Expiration Mean for Suppliers?

As of August 27, 2026, CMS has allowed its six-month nationwide moratorium on initial Medicare enrollment for seven categories of DMEPOS medical supply companies to expire. Suppliers who were blocked from submitting new enrollment applications since February 27, 2026, can now file through PECOS or paper CMS-855S forms. CMS is expected to process a high volume of backlogged applications, and suppliers planning to participate in the 2028 Competitive Bidding Program should submit promptly.

• Who is affected: New DMEPOS medical supply companies across all seven CMS-designated supplier categories that were blocked from initial Medicare enrollment since February 2026.
• What to do first: Prepare and submit your CMS-855S application through PECOS as soon as possible, since processing delays are expected due to the volume of pending applications.
• Key exception: Florida’s Agency for Health Care Administration (AHCA) maintains its own state Medicaid DMEPOS moratorium through September 20, 2026, and CMS’s hospice and home health agency enrollment moratorium remains separately in effect.

What Changed on August 27, 2026

On February 27, 2026, CMS imposed a nationwide temporary moratorium on initial Medicare enrollment for DMEPOS medical supply companies. The action was published in the Federal Register (Doc. 2026-03971), citing longstanding concerns from CMS, HHS-OIG, and the Department of Justice about fraudulent billing schemes involving braces, catheters, diabetic supplies, and other high-risk supply categories.

The moratorium applied to seven specific supplier categories, all classified as medical supply companies with various personnel designations. Any initial enrollment application or change in majority ownership (CIMO) application submitted on or after February 27 was denied outright. Existing enrolled suppliers were unaffected and continued billing Medicare normally.

That six-month period ended on August 27, 2026. CMS did not publish a Federal Register notice extending the moratorium, which means it has expired by operation of its own terms. The agency is now accepting new initial enrollment applications from DMEPOS suppliers in all 50 states.

In our experience handling Medicare provider enrollment applications for DME suppliers, the most common question right now is whether applications can be submitted immediately. The answer is yes, but processing timelines will be longer than normal given the backlog.

Who Does the DMEPOS Moratorium Expiration Apply To?

The moratorium applied specifically to seven categories of DMEPOS medical supply companies. If your organization falls into any of these categories and you were unable to enroll between February and August 2026, you can now submit your initial application:

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 Registered Pharmacist
7. Medical Supply Company with Respiratory Therapist

The moratorium did not apply to entities whose principal function is not furnishing DMEPOS. Physician practices, hospitals, pharmacies, and other providers whose primary business is not DME supply were generally exempt. The principal-function test determined applicability, not the supplier’s occasional sale of DME items.

Existing enrolled suppliers kept their billing privileges throughout the moratorium. This expiration affects only organizations that needed to enroll for the first time or needed new enrollment due to a majority ownership change.

Why CMS Imposed the Moratorium

CMS has had longstanding concerns about healthcare fraud conducted by individuals and companies in the DMEPOS industry. The Federal Register notice cited numerous criminal fraud convictions involving DMEPOS suppliers, elevated rates of revocations, payment suspensions, and law enforcement actions in the affected supplier categories.

The moratorium followed additional anti-fraud provisions that took effect January 1, 2026. Under those rules, a majority change in direct ownership within 36 months of the last change requires the DMEPOS supplier to submit a new enrollment application rather than a change of information update. This 36-month rule, combined with the moratorium, effectively froze most ownership transactions in the DMEPOS space for six months.

The broader enforcement environment has not changed. CMS continues to pursue program integrity measures aggressively, and the separate moratorium on hospice and home health agency enrollments remains in effect. Suppliers re-entering the enrollment process should expect heightened scrutiny on applications, including site visits, background checks, and surety bond verification.

How to Submit Your DMEPOS Enrollment Application Now

With the moratorium lifted, the enrollment process follows the standard CMS-855S pathway. Here is what to do in order:

1. Verify your DMEPOS accreditation. Medicare requires DMEPOS suppliers to hold valid accreditation from a CMS-approved accrediting organization before enrollment. If your accreditation lapsed during the moratorium, renew it before submitting.
2. Obtain your NPI. Every DMEPOS supplier needs a Type 2 (organizational) NPI from NPPES before submitting CMS-855S.
3. Secure a surety bond. CMS requires a $50,000 surety bond from an authorized surety company. The bond must be in place at the time of application.
4. Complete the CMS-855S application. Submit through PECOS for faster processing (PECOS submissions average 15 days faster than paper) or use the current paper form.
5. Prepare for the site visit. CMS conducts unannounced site inspections for DMEPOS suppliers. Your physical location must be accessible, properly signed, and stocked with the equipment types you intend to supply.
6. Submit state-level enrollment where required. Several states require separate Medicaid enrollment for DMEPOS suppliers. Check your state’s Medicaid portal requirements in addition to the federal application.
7. Monitor application status. Track your application through the PECOS dashboard or by contacting the National Supplier Clearinghouse.

Common Mistakes After a Moratorium Expiration

A rush of applications after a moratorium creates predictable problems. We see similar patterns whenever CMS reopens an enrollment pathway. Here are the mistakes that cause the most delays:

Submitting before accreditation is current. The number one rejection reason for DMEPOS enrollment is an expired or missing accreditation certificate. CMS will deny the application, and the supplier has to restart after obtaining valid accreditation. Verify your accreditation status with your accrediting organization before filing anything.

Using outdated application forms. CMS revised the CMS-855 application forms in August 2026. If you downloaded the CMS-855S before the revision, your application may be returned. Download the current version directly from CMS before submitting.

Incomplete ownership disclosures. The 36-month ownership rule means CMS is scrutinizing ownership structures more closely. Every individual or entity with a 5% or greater direct or indirect ownership interest must be disclosed, along with all managing employees.

Missing the competitive bidding timeline. Suppliers planning to bid in the 2028 DMEPOS Competitive Bidding Program need active enrollment well before the bidding window opens. Processing delays after the moratorium could push enrollment completion into 2027 if applications are submitted late.

Ignoring state-level requirements. Federal Medicare enrollment does not automatically cover state Medicaid. Many DMEPOS suppliers serve dual-eligible patients and need both. Florida’s AHCA moratorium on Medicaid DMEPOS enrollment runs separately through September 20, 2026.

What Is Still Restricted vs. What Is Open

The DMEPOS moratorium expiration does not mean all Medicare enrollment restrictions are lifted. Here is the current status as of August 2026:

Should You Handle DMEPOS Enrollment In-House or Outsource?

For suppliers enrolling for the first time, the standard CMS-855S process involves accreditation verification, NPI registration, surety bond procurement, ownership disclosure, the application itself, and the site visit. Each step has its own timeline, and a single incomplete field can return the application for correction, adding 30 to 60 days.

Outsourcing enrollment to a credentialing and enrollment firm is particularly valuable after a moratorium, when application volumes spike and CMS processing times extend. Providers who have been through Medicare enrollment with us know that we handle follow-up with the National Supplier Clearinghouse, monitor application status, and resolve deficiency notices before they become rejections.

The cost of delayed enrollment is real. Every month without active Medicare billing privileges is a month of unbillable services and lost revenue for a DME supplier that is otherwise ready to operate.

Frequently Asked Questions

Next Steps

If you are a new DMEPOS supplier ready to enroll, start by verifying your accreditation, gathering your ownership documentation, and submitting through PECOS. For more on the Medicare enrollment application process, see our CMS-855 application guide.

If you have questions about how the moratorium expiration interacts with state-level enrollment requirements or the 2028 Competitive Bidding Program, reach out to our enrollment team.