Downcoded

Why One Prior Authorization List Got 90 Days and the Other Got 35

Forty orthosis and bone stimulator codes become prior authorization codes on October 15 for any DMEPOS supplier Medicare considers new. The list lives in a four-page PDF, the Federal Register has never printed the words probationary prior authorization, and the regulation CMS cites counts four ways to become new when the announcement names two.


Forty HCPCS codes become prior authorization codes on October 15.

The document that says so is a four-page PDF headed "Updated 9/1/2026." No docket number, no comment period, no author.

Thirty-eight orthoses and two bone growth stimulators, each with the same effective date in the right-hand column.

CMS announced it this morning, in the Thursday newsletter, between a Rhode Island workforce grant and a reminder about CPAP billing.

The List That Never Went to the Federal Register

The item is four sentences long. Effective October 15, CMS will "implement a nationwide 1-year probationary prior authorization (PPA) process for newly enrolled suppliers and suppliers undergoing a change of ownership" and will "require prior authorization as a condition of payment for certain DMEPOS items."

Condition of payment. That phrase is the whole of it: no provisional affirmation, no payment.

We went looking for the rulemaking. The Federal Register's full-text index contains zero documents, across its entire history, using the phrase "probationary prior authorization." Not a proposed rule, not a final rule, not a notice. The CY2026 home health final rule is the most recent rule to touch DMEPOS prior authorization, and it does not mention section 1866(j)(3), does not mention 42 CFR 424.527, and does not contain the words "newly enrolled" anywhere in its text.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

$50 a month, or $500 a year.