On February 25, 2026, the Trump Administration announced several initiatives as part of a broader effort to address health care fraud. This includes a Nationwide Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Enrollment Moratorium and the launch of a Request for Information (RFI) Related to Comprehensive Regulations To Uncover Suspicious Healthcare (CRUSH) by the Centers for Medicare & Medicaid Services (CMS). This comes amongst other Medicare program integrity initiatives, such as the agency announcing they intend to publish information on providers/suppliers whose participation in the Medicare program has been revoked, including the reason for revocation and corresponding National Provider Identifier (NPI).
DMEPOS Enrollment Moratorium
CMS has determined that medical supply companies have a high potential for fraud, waste, or abuse and the agency believes that a moratorium on the enrollment of medical supply companies into Medicare could assist in curtailing this activity. The DMEPOS Medical Supply Company Moratorium will last for 6 months, however CMS has the authority to extend it in 6-month increments if deemed necessary. This will be imposed nationwide (anywhere in the United States, including all states, territories, and the District of Columbia). While according to the Federal Register notice, the moratorium took effect February 27, 2026, the Community Health Accreditation Partner (CHAP) reports that CMS confirmed with them that the effective date is February 25, 2026.
Beginning on this effective date, no new DMEPOS suppliers of the identified supplier types[1] (as well as no new practice locations of these supplier types) will be enrolled in Medicare unless the enrollment application was received prior to the effective date. Since this moratorium applies to initial applications, CMS notes this includes non-exempt changes in majority ownership (CIMOs) under 42 CFR 424.551. At this time, CMS notes their belief that it is in the best interest of Medicaid and Children’s Health Insurance Program (CHIP) beneficiaries to leave it to state’s discretion as to whether a DME moratorium should be applied to their Medicaid and/or CHIP program, but notes that “CMS encourages each state to, as appropriate, implement a DME provider moratorium tailored to the specifics of their beneficiary population as well as any geographic considerations.”
CRUSH RFI and Regulatory Framework
The agency’s RFI that was recently released seeks stakeholder feedback on potential regulatory changes that may be included in a possible upcoming CRUSH proposed rule and other changes that could be implemented to further address fraud. Comments are due March 30, 2026. CMS seeks feedback on a range of topics to inform the development of more effective fraud-prevention strategies. Topics include, but are not limited to: ways CMS can strengthen its “fraud-fighting toolbox” to prevent fraud, waste, and abuse; how to reduce Medicare fraud related to laboratory tests, including genetic tests and molecular diagnostic tests; ways to address fraud by non-participating DMEPOS suppliers; the impact of reducing the Medicare Parts A and B 1-calendar year claim filing deadline for high-risk items and services, including DMEPOS; and how AI can be used to more accurately and efficiently abstract diagnoses from medical record documentation as part of medical records review, including feedback on AI solutions that can address coding issues related to over and underpayments, and how AI can increase hospital billing efficiency and accuracy.
Next Steps and Ongoing Analysis
Applied Policy will continue to monitor developments across this space and assess their implications for stakeholders navigating these changes and will provide a follow-up analysis in our upcoming April newsletter.
[1] The DMEPOS supplier types identified as being under the scope of this moratorium are: 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, and Medical supply company with respiratory therapist.