As Applied Policy has previously reported, on February 25, 2026, the Trump Administration announced several initiatives as part of a broader effort to address healthcare fraud. These included a Nationwide Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Enrollment Moratorium and the launch by the Centers for Medicare & Medicaid Services (CMS) of a Request for Information (RFI) Related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH), for which the comment period ended on March 30, 2026. This comes alongside other Medicare program integrity initiatives, including the agency’s plan to publish information on providers/suppliers whose participation in the Medicare program has been revoked, including the reason for revocation and corresponding National Provider Identifier (NPI).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 Developments
Since the announcement of the DMEPOS Medical Supply Company Medicare Enrollment Moratorium, stakeholders have raised concerns about its potential implications.
In announcing the moratorium, CMS indicated that it believed it was in the best interest of Medicaid and Children’s Health Insurance Program (CHIP) beneficiaries if individual states decided whether to apply a DME moratorium to their Medicaid and/or CHIP program. The agency noted 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.”
In late March, Florida’s Agency for Health Care Administration (AHCA) announced the imposition of an initial 6-month moratorium on enrollment of new Medicaid providers for DMEPOS. Florida Medicaid is the first state Medicaid program to take this step following the announcement of the Medicare enrollment moratorium. This comes after CMS Administrator, Dr. Mehmet Oz, identified the state as a “hot spot for health care fraud.” AHCA Secretary Shevaun Harris noted that “this moratorium is just one example of the many efforts being put in place to curb fraud, waste, and abuse in the Medicaid program and to ensure Medicaid recipients are able to receive care from high quality providers.”
In the context of the upcoming Remote Item Delivery (RID) Competitive Bidding Program (CBP) round, the moratorium may limit competition by restricting the geographic expansion of existing and new suppliers. Suppliers that may have planned to expand their capabilities to support a bid under the RID CBP by opening new Medicare-enrolled locations are now unable to do so. As a result, stakeholders are seeking an exemption from the moratorium for providers that have been in operation for at least 36 months. Similar waivers have been used in a previous home health moratorium.
Stakeholders, while supportive of the Administration’s efforts to curb fraud, waste, and abuse, are concerned that legitimate providers and suppliers may be adversely affected. There is apprehension in the DMEPOS community that this could in turn affect patient access to DMEPOS items and preparations for the upcoming RID CBP round.
CRUSH RFI Developments
The agency’s RFI sought stakeholder feedback on regulatory changes that could be included in a future CRUSH proposed rule. The RFI drew over 700 responses. As this article goes to press, only those posted directly by submitters are currently available for review. These have largely focused on the need for the agency to leverage existing tools while advocating for a strategic and nuanced approach to implementation of any new tools to fight fraud, waste, and abuse. AAHomecare has advocated for the use of existing technologies to enhance real-time review and monitor electronic funds transfer (EFT) activity of new suppliers, among other suggestions. The National Association of Medicaid Directors (NAMD) noted many opportunities and avenues for CMS to take to fight fraud, waste, and abuse including expanding the use of artificial intelligence (AI) tools and more frequent reverification of high-risk providers.
Stakeholders have provided a range of nuanced policy recommendations to enhance CMS’s fraud-fighting toolkit. Applied Policy will continue to monitor how the agency incorporates these recommendations into future policy.