What Are the New DMEPOS Prior Authorization Requirements for Podiatry?
As of October 28, 2026, CMS is expanding the Required Prior Authorization List for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) to include 82 items, adding 8 new HCPCS codes that require prior authorization before Medicare will process payment. The Master List of items potentially subject to these requirements now includes 550 codes, and the Face-to-Face Encounter and Written Order Prior to Delivery List has grown to 105 items. For podiatry practices that prescribe ankle-foot orthoses, therapeutic footwear, or wound care supplies, these changes add a layer of documentation and timing requirements that did not exist before.
Who is affected:
Any podiatry practice that orders, prescribes, or furnishes DMEPOS items covered by Medicare, particularly ankle-foot orthoses (AFOs), knee orthoses, and custom-fitted orthotic devices.
When it takes effect:
October 28, 2026, for the latest round of additions. Some codes, including L1932 (carbon fiber AFO), already require prior authorization nationwide as of April 13, 2026.
What to do now:
Audit your current DMEPOS ordering workflows, verify which codes your practice uses against the updated Required Lists, and confirm that your documentation meets the face-to-face encounter and written order requirements before the October 28 deadline.
What Changed in the July 2026 Federal Register Update
On July 30, 2026, CMS published a Federal Register notice finalizing updates to the DMEPOS Master List, the Required Prior Authorization List, and the Required Face-to-Face Encounter and Written Order Prior to Delivery List. These lists govern which Medicare DMEPOS items carry additional payment conditions beyond the standard claims submission process.
The Master List grew from 530 to 550 items with the addition of 22 new HCPCS codes. The Master List itself does not impose requirements on providers. It serves as a library of items CMS has flagged as vulnerable to unnecessary utilization. From that library, CMS selects items for either the Required Prior Authorization List or the Required Face-to-Face Encounter and Written Order Prior to Delivery List, and those selections are what create actual compliance obligations.
Eight new HCPCS codes were added to the Required Prior Authorization List, bringing the total to 82 items. The Required Face-to-Face Encounter and Written Order Prior to Delivery List expanded to 105 items. These additions follow a pattern CMS has maintained since 2020, when it harmonized its DMEPOS oversight lists under 42 CFR 414.234 and 42 CFR 410.38.
In our experience matching providers with billing partners, the practices that struggle most with DMEPOS compliance are the ones that treat the prior authorization process as an afterthought rather than a built-in step in their clinical workflow. The billing companies we vet consistently flag prior authorization gaps as one of the top reasons podiatry DMEPOS claims get denied on first submission.
APMA has publicly opposed the expansion of prior authorization in the Medicare program. In a statement earlier this year, APMA called on CMS to reverse its decision to require prior authorization for HCPCS code L1932, an ankle-foot orthosis essential for treating conditions that affect mobility and function. APMA has argued that prior authorization delays access to medically necessary care and increases administrative burden on providers, and has urged CMS to rely instead on targeted, data-driven programs to address fraud and improper payments.
Which DMEPOS Codes Now Require Prior Authorization for Podiatry?
Not every code on the expanded lists directly affects podiatry practices, but several do. The most relevant codes for podiatrists fall into the orthoses and lower extremity device categories. Here is a breakdown of the codes podiatry practices should review.
| HCPCS Code | Description | Requirement / Effective Date |
|---|---|---|
| L1932 | AFO, rigid anterior tibial section, total carbon fiber or equivalent, prefabricated, custom fitted | Prior Authorization, nationwide since April 13, 2026 |
| L0651 | LSO, sagittal-coronal control, rigid shell, prefabricated, off-the-shelf | Prior Authorization, effective October 28, 2026 |
| L1844 | KO, single upright, thigh and calf, adjustable joint, custom fabricated | Prior Authorization, phased rollout through October 2026 |
| L1846 | KO, double upright, thigh and calf, adjustable joint, custom fabricated | Prior Authorization, phased rollout through October 2026 |
| L1851 | KO, single upright, prefabricated, off-the-shelf | Prior Authorization, phased rollout through October 2026 |
| L1852 | KO, double upright, prefabricated, off-the-shelf | Prior Authorization, phased rollout through October 2026 |
Podiatrists who prescribe AFOs for patients with drop foot, Charcot neuroarthropathy, or post-surgical ankle stabilization should pay close attention to L1932. This is the code APMA has specifically flagged as problematic. The prior authorization requirement applies to claims submitted to a DME Medicare Administrative Contractor (MAC), which means it affects the supplier who furnishes the device, not the prescribing podiatrist directly. However, the prescribing podiatrist’s documentation is what the supplier needs to obtain approval.
CMS’s Comprehensive Error Rate Testing (CERT) program has consistently identified orthoses as one of the top 20 DMEPOS categories with improper payments. According to CMS’s 2024 Medicare Fee-for-Service Supplemental Improper Payment Data, the improper payment rate for podiatry care overall stands at 11.2%, with a projected improper payment amount of $216.9 million. That rate is one reason CMS keeps expanding oversight on DMEPOS items commonly prescribed by podiatrists. For a closer look at how CMS has been enforcing documentation standards on podiatry DMEPOS items, see our coverage of diabetic shoe billing and improper payment risks.
How Do These Changes Affect Podiatry Practices?
The practical impact depends on how many DMEPOS items your practice prescribes and whether you furnish those items in-house or refer patients to an external supplier. Either way, the documentation burden falls on the prescribing provider.
For practices that prescribe AFOs, knee orthoses, or custom-fitted orthotic devices, the prior authorization process means the supplier must submit a request to the DME MAC with all required documentation before furnishing the item to the patient. That documentation starts with the podiatrist. If the clinical record does not include the right elements, the supplier’s request gets non-affirmed, the patient does not receive the device on time, and the practice hears about it.
For practices that also act as DMEPOS suppliers (dispensing therapeutic shoes, for example), the compliance obligation is direct. You must submit the prior authorization request yourself, wait for a provisional affirmation from CMS or its review contractor, and only then furnish the item and submit the claim.
The face-to-face encounter requirement adds another layer. For items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List (now 105 items), the treating practitioner must have a face-to-face encounter with the patient, document the medical necessity, and provide a written order to the supplier before the item can be delivered. The encounter cannot happen after the fact. This is not new in concept, but the expanded list means more podiatry-adjacent devices now carry this requirement.
One question we hear constantly from practice managers is whether prior authorization guarantees payment. It does not. A provisional affirmation from the DME MAC means the documentation appears to meet Medicare requirements at the time of review. CMS can still deny the claim on post-payment review if the documentation does not hold up under closer scrutiny. Practices that want a deeper look at the billing compliance picture should review our revenue cycle management strategies for podiatry.
Navigating DMEPOS prior authorization adds time and complexity to your billing workflow.
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What Documentation Does CMS Require for DMEPOS Prior Authorization?
CMS requires that prior authorization requests include evidence the item complies with all applicable Medicare coverage, coding, and payment rules. For orthoses prescribed by podiatrists, the documentation package typically needs to include the following elements.
The specific requirements for ankle-foot and knee-ankle-foot orthoses are spelled out in the DME MAC Local Coverage Determination (LCD) and the accompanying Policy Article. According to the CGS Administrators documentation checklist (revised May 11, 2026), AFO and KAFO claims require medical records documenting an ambulatory beneficiary with weakness or deformity of the foot and ankle who requires stabilization for medical reasons and has the potential to benefit functionally. For custom-fitted orthoses, the supplier’s records must include a detailed description of why the modifications were necessary and what modifications were performed at the time of fitting.
The standard written order for all DMEPOS items must include the beneficiary name or Medicare Beneficiary Identifier (MBI), the item description, the treating practitioner’s signature, and the date of the order. This written order must be submitted to the supplier before the supplier submits a claim for Medicare payment.
Providers often come to us after learning their DMEPOS claims were denied because the prescribing physician’s documentation was incomplete. The most common gaps we see across the billing companies we vet are missing face-to-face encounter documentation, unsigned or undated written orders, and chart notes that describe the device but fail to document why the patient specifically needs that level of device rather than a less complex alternative. Keeping a podiatry billing and coding cheat sheet updated with the current DMEPOS documentation requirements helps front-desk and clinical staff catch these gaps before claims go out.
How to Prepare Your Podiatry Practice Before October 28
With approximately one month before the expanded requirements take effect, podiatry practices should take the following steps to avoid claim disruptions.
- Audit your current DMEPOS ordering volume. Pull a report of every DMEPOS item your practice has prescribed or furnished in the past 12 months. Cross-reference those HCPCS codes against the updated Master List, Required Prior Authorization List, and Required Face-to-Face Encounter List, all available at go.cms.gov/DMEPOSPA.
- Update your EHR templates. Add structured fields for face-to-face encounter documentation, medical necessity statements, and DMEPOS-specific order elements. If your chart note templates do not prompt the clinician for these fields, they will be missed.
- Coordinate with your DMEPOS suppliers. Contact every supplier you work with and confirm they are prepared for the new prior authorization codes. Ask them what documentation format they need from your practice and how far in advance they need it to submit the prior authorization request before furnishing the device.
- Train your clinical and billing staff. Schedule a training session specifically on the updated lists. Walk through a sample AFO order from face-to-face encounter through prior authorization submission to claim payment. Identify the handoff points where documentation gaps typically occur.
- Establish a prior authorization tracking system. Prior authorization requests can be provisionally affirmed or non-affirmed. Non-affirmed requests can be resubmitted with additional documentation. You need a system to track the status of every open request so devices are not furnished before approval and patients are not left waiting without updates.
- Subscribe to your DME MAC’s email notifications. Each Medicare Administrative Contractor publishes updates when LCDs are proposed, revised, or finalized. Noridian and CGS Administrators are the two DME MACs. Signing up for their notifications is the most direct way to catch policy changes before they affect your claims.
Common Prior Authorization Mistakes That Trigger Denials
Prior authorization is designed to confirm coverage eligibility before a claim is submitted, but it introduces several failure points that podiatry practices need to manage proactively.
The most common mistake is furnishing the device before receiving provisional affirmation. If a supplier delivers an AFO to the patient before the prior authorization request is affirmed, the claim will be denied. There is no retroactive approval pathway.
The second most common issue is submitting incomplete documentation. A prior authorization request that is missing the face-to-face encounter note, the written order, or the medical necessity statement will be non-affirmed. The supplier can resubmit, but the delay pushes back the patient’s access to the device.
A third issue specific to podiatry involves code selection for prefabricated versus custom-fitted orthoses. As CMS has noted in its Policy Article for AFO/KAFO billing, there is no physical difference between orthoses coded as custom fitted and those coded as off-the-shelf. The distinction is in the fitting work performed by a qualified practitioner. If the documentation does not clearly describe the modifications performed during fitting, the code selection can be challenged and the prior authorization can be non-affirmed.
Finally, practices sometimes confuse the Master List with the Required Lists. Being on the Master List does not mean an item requires prior authorization or a face-to-face encounter. Only items that appear on the Required Prior Authorization List or the Required Face-to-Face Encounter and Written Order Prior to Delivery List carry those specific obligations. Treating every Master List item as if it requires prior authorization wastes time. Ignoring the Required Lists entirely causes denials.
There is one positive development worth noting. CMS announced earlier in 2026 that certain DMEPOS suppliers will be eligible for an exemption from prior authorization requirements. APMA views this as a step toward a “gold carding” approach, where suppliers with strong compliance track records face less administrative scrutiny. This exemption does not eliminate the documentation requirements from the prescribing podiatrist, but it can speed up the process for patients working with qualified suppliers.
Frequently Asked Questions
No. A provisional affirmation means the documentation appeared to meet Medicare requirements at the time of review. CMS can still deny the claim on post-payment review if the documentation does not hold up or if the item was not furnished as described in the prior authorization request.
The prior authorization request is submitted by the supplier furnishing the DMEPOS item, not the prescribing physician. However, the prescribing podiatrist provides the clinical documentation the supplier needs to obtain approval. Incomplete provider documentation is the most common reason prior authorization requests are non-affirmed.
The supplier can resubmit the request with additional or corrected documentation. There is no limit on resubmissions. However, the item cannot be furnished to the patient until a provisional affirmation is received. Each resubmission cycle adds days or weeks of delay for the patient.
The face-to-face encounter must occur before the written order is created. It does not have to happen on the same day, but the clinical documentation must establish that the encounter informed the decision to order the specific device. A face-to-face encounter documented after the written order date will not meet the requirement.
As of October 2026, therapeutic shoes and inserts for diabetic patients (A5500, A5501, and related codes) are not on the Required Prior Authorization List. However, they do appear on the Master List, which means CMS has flagged them as potentially vulnerable to unnecessary utilization. They could be moved to a Required List in a future update.
CMS publishes the current Required Prior Authorization List as a PDF on its DMEPOS oversight page. The direct URL is go.cms.gov/DMEPOSPA. The list is updated through Federal Register notices, and the most recent update was published July 30, 2026, with changes effective October 28, 2026.
Next Steps
- Review the updated DMEPOS Required Lists at the CMS DMEPOS oversight page before October 28 to confirm which items your practice prescribes.
- If your practice is managing DMEPOS documentation in-house and finding it difficult to keep up with the expanding compliance requirements, a billing company with podiatry-specific DMEPOS expertise can handle the tracking, documentation coordination, and claim follow-up for you.
Finding the right billing partner for your podiatry practice takes one step.
We match providers with vetted medical billing companies that specialize in podiatry claims, DMEPOS documentation, and Medicare compliance. The quote is free. The match takes 30 minutes.
