The 2026 Moratorium on New Medical Supply Companies

On February 27, 2026, CMS imposed a six-month nationwide moratorium on the Medicare enrollment of new DMEPOS "medical supply companies" (CMS-6099-N, 91 FR 9855). For six months, a company of that type could not enroll in Medicare at all, and an enrolled one could not add a new location. CMS's competitive bidding contractor announced on August 27, 2026 that the moratorium "has now expired as of August 27, 2026," and that the National Provider Enrollment contractors "are once again accepting initial enrollment applications." It left a backlog of would-be suppliers and a clear signal about where CMS sees risk.

Which supplier types did the moratorium cover?

Seven Medicare DMEPOS supplier types, all variations of one:

• Medical supply company
• Medical supply company with orthotics personnel
• Medical supply company with pedorthic personnel
• Medical supply company with prosthetics personnel
• Medical supply company with prosthetic and orthotic personnel
• Medical supply company with registered pharmacist
• Medical supply company with respiratory therapist

For the moratorium, CMS defined a medical supply company as "a business whose principal function is to furnish DMEPOS supplies (regardless of supply type) directly to another party," such as patients with a medical order (including by mail order), other providers and suppliers, or both. A "with personnel" type had at least one such professional in an employment, advisory, contractual or other role.

Who could still enroll during the moratorium?

CMS said a grocery store's, pharmacy's or medical provider's principal function is typically not furnishing DMEPOS, so the moratorium "would generally not apply" to them. The notice says pharmacies, physicians, hospitals, physical therapists and other DMEPOS supplier types remained able to open new practice locations. The general exceptions in 42 CFR 424.570(a)(1) also applied: the moratorium did not reach changes of practice location (except into a moratorium area), changes of information such as phone numbers, most changes of ownership, or any application the contractor received before February 27, 2026.

CMS also warned against workarounds. It said it would "very closely screen" applications during the moratorium, including site visits and online research, and that a medical supply company that tried to enroll as another supplier type could face denial and a reapplication bar of up to 10 years under 42 CFR 424.530(a)(4) and (f), plus referral to the Office of Inspector General.

Did the 36-month ownership rule interact with it?

Yes. Under 42 CFR 424.551, a buyer that acquires more than 50 percent of a DMEPOS supplier within 36 months of its initial enrollment (or its last majority change) must enroll as a new supplier with new accreditation. CMS said that re-enrollment "would constitute an initial enrollment," so the moratorium blocked it, and the usual moratorium exception for changes of ownership did not apply. A sale of a recently enrolled medical supply company during the moratorium could leave the buyer unable to bill. See the 36-month ownership rule.

Why did CMS single out medical supply companies?

The notice cites CMS data and Inspector General reports. Among the points CMS made:

• From 2023 to October 2025, medical supply company specialties had a 17 percent revocation rate, "nearly triple the rate for other DMEPOS supplier types."
• All seven types ranked in the top 20 of more than 80 DMEPOS specialty types for the share revoked at least once since 2023, and also ranked high for payment suspensions, law enforcement referrals and complaints.
• Medical supply companies submitted more than 80 percent of the more than 1.5 million off-the-shelf brace claim lines from DMEPOS suppliers between 2023 and late October 2025.
• In early 2023, CMS identified a urinary catheter billing scheme involving 15 DMEPOS companies that had recently changed ownership, and revoked all 15.

CMS also reported that there were more than 6,000 enrolled medical supply companies as of October 2025, about 7.5 percent of the nearly 80,000 enrolled DMEPOS suppliers, with about 600 new ones enrolling in a typical year. In 2025 there were 79,360 approved DMEPOS supplier enrollments, an 8.3 percent decrease since 2023.

Did the moratorium apply to Medicaid?

Not automatically. CMS left it to each state to decide whether some form of DME moratorium suits its Medicaid and CHIP programs, while encouraging states to consider one and offering consultation. Some states already have their own limits; New Jersey's Medicaid rules, for example, have barred new fee-for-service medical supply providers since July 1, 2006 unless the state finds a special need (N.J.A.C. 10:59-1.3). See Medicaid DME enrollment.

How did it end, and could it come back?

A CMS moratorium lasts six months and may be extended in six-month increments, each extension announced in the Federal Register (42 CFR 424.570(b)). CMS's competitive bidding site said in June and July 2026 that it had not decided whether to extend this one. On August 27, 2026 it announced the expiration and urged Round 2028 bidders to submit completed enrollment applications as soon as possible. We found no extension notice in the Federal Register.

Nothing stops CMS from imposing another moratorium on the same or other supplier types if it again finds a significant potential for fraud, waste or abuse (424.570(a)(2)). In 2026 it also announced separate nationwide moratoria on new home health agencies and hospices. And the notice says that once a moratorium is lifted, the supplier types that could not enroll are screened at the "high" level if they apply within six months (42 CFR 424.518(c)(3)(iii)). New DMEPOS suppliers are already high risk, with fingerprints for every 5 percent owner and a site visit (424.518(c)).

What does it mean for a supplier applying now?

• Apply complete, and apply once. A denial now costs more than it did, because the window could close again. Accreditation must already be in place, along with state licenses, the location, insurance and the $50,000 bond.
• Describe the business accurately. CMS has said it checks whether a supplier is really a medical supply company. Choose the supplier type that matches what you do.
• Plan for competitive bidding. If you will bid in Round 2028, the bid window is currently targeted to close March 10, 2027, and every state license must be in PECOS by then.
• If a moratorium is imposed again, the application fee is refunded when an application is denied because of it (42 CFR 424.514), and an appeal can only argue whether the moratorium applies to you (42 CFR 498.5(l)(4)), according to the notice.

Our post on enrolling a medical supply company after the moratorium walks through the sequence.

How do we help a new supplier get enrollment-ready?

We prepare the CMS-855S, the supplier standards evidence and the bond and insurance documents, and, once your authorized official approves us as a PECOS surrogate, enter and submit the application for your official to sign. The Medicare DMEPOS Enrollment Package is $1,295 for the first location; Accreditation Readiness is $2,495; a $149 Readiness Review checks whether you are ready to file at all. You pay the CMS application fee, the accreditation fee and the bond premium directly. No one can promise enrollment or a date, and a new moratorium could change the timeline overnight. The enrollment hub explains the order of operations.