CMS Updates to Master List, F2F/WOPD List, and Required Prior Authorization

Published in Member Communities on January 15, 2026

On Wednesday, January 13, 2026, CMS released the annual updates to the Master List of DMEPOS Items Potentially Subject to Face-to-Face Encounter and Written Orders Prior to Delivery and/or Prior Authorization Requirements.

The Master List serves as a library of items that have been identified as potential vulnerabilities to the Trust Fund, from which items may be selected to be placed on either the Required Face-to-Face Encounter and Written Orders Prior to Delivery List (the “F2F/WOPD List”) and/or Required Prior Authorization List. Only those items that are selected and announced via Federal Register notice are subject to such regulatory conditions of payment.

F2F/WOPD List—New Non-Statutorily Required Items

HCPCS

Description

E0424

Stationary compressed gaseous oxygen system, rental; includes container, contents, regulator, flowmeter, humidifier, nebulizer, cannula or mask, and tubing.

E0431

Portable gaseous oxygen system, rental; includes portable container, regulator, flowmeter, humidifier, cannula or mask, and tubing.

E0433

Portable liquid oxygen system, rental; home liquefier used to fill portable liquid oxygen containers, includes portable containers, regulator, flowmeter, humidifier, cannula or mask and tubing, with or without supply reservoir and contents gauge.

E0434

Portable liquid oxygen system, rental; includes portable container, supply reservoir, humidifier, flowmeter, refill adaptor, contents gauge, cannula or mask, and tubing.

E0439

Stationary liquid oxygen system, rental; includes container, contents, regulator, flowmeter, humidifier, nebulizer, cannula or mask, & tubing.

E1390

Oxygen concentrator, single delivery port, capable of delivering 85 percent or greater oxygen concentration at the prescribed flow rate.

E1391

Oxygen concentrator, dual delivery port, capable of delivering 85 percent or greater oxygen concentration at the prescribed flow rate, each.

E1392

Portable oxygen concentrator, rental.

The face-to-face encounter must be documented in the pertinent portion of the medical record (for example, history, physical examination, diagnostic tests, summary of findings, progress notes, treatment plans, or other sources of information that may be appropriate).

The supporting documentation must include subjective and objective beneficiary specific information used for diagnosing, treating, or managing a clinical condition for which the DMEPOS item(s) is ordered. Upon request by CMS or its review contractors, a supplier must submit additional documentation to support and substantiate the medical necessity for the DMEPOS item.

For items on the Required List other than power mobility devices (PMDs), the treating practitioner who conducted the face-to-face encounter doesn't need to be the prescriber for the DMEPOS item. The prescriber must verify that a qualifying face-to-face encounter occurred within six months of the date of their order and have documentation of that encounter. For PMDs, the treating practitioner must conduct the face-to-face encounter.

A qualifying face-to-face encounter is required within six months of writing the order for any item on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.

Exceptions – When a Face-to-Face Encounter is not required:

Replacing the same item after its reasonable useful lifetime (if policy specific rules are met).
Replacing a power mobility device (PMD) in the same performance group that was previously covered by Medicare during the 5-year useful lifetime.
- Note: Replacement during an item’s useful lifetime is limited to situations involving loss or irreparable damage from a specific accident or natural disaster (e.g., fire, flood, etc.).

A valid WOPD contains the same information as a Standard Written Order (SWO). The only difference is that suppliers must have the SWO before delivering the item to the beneficiary. The order date must be on or before the date of delivery. The WOPD must be completed within six months after the face-to-face encounter.

In 2024, CMS published the most recent iteration of the Required Face-to-Face Encounter and Written Order Prior to Delivery List. There are currently 75 items on the list, including 46 PMDs that were included per statute. This list is also available on the CMS website.

Additions to the Required Prior Authorization List

HCPCS

Description

L0651

Lumbar-sacral orthosis, sagittal-coronal control, rigid shell(s)/panel(s), posterior extends from sacrococcygeal junction to t-9 vertebra, anterior extends from symphysis pubis to xyphoid, produces intracavitary pressure to reduce load on the intervertebral discs, overall.

L1844

Knee orthosis, single upright, thigh and calf, with adjustable flexion and extension joint (unicentric or polycentric), medial-lateral and rotation control, with or without varus/valgus adjustment, custom fabricated.

L1846

Knee orthosis, double upright, thigh and calf, with adjustable flexion and extension joint (unicentric or polycentric), medial-lateral and rotation control, with or without varus/valgus adjustment, custom fabricated.

L1852

Knee orthosis, double upright, thigh and calf, with adjustable flexion and extension joint (unicentric or polycentric), medial- lateral and rotation control, with or without varus/valgus adjustment, prefabricated, off-the-shelf.

L1932

Ankle foot orthosis, rigid anterior tibial section, total carbon fiber or equal material, prefabricated, includes fitting and adjustment.

E0651

Pneumatic compressor, segmental home model without calibrated gradient pressure.

E0652

Pneumatic compressor, segmental home model with calibrated gradient pressure.

The Required Prior Authorization List is selected from the Master List, and those selected items require prior authorization as a condition of payment.

The Required Prior Authorization List was last updated in 2024 and currently includes 67 items. All the lists discussed in this notice are available on the CMS website.

Additions to the Master List

HCPCS	Description
A4238	Supply allowance for adjunctive, non-implanted continuous glucose monitor (CGM), includes all supplies and accessories, 1 month supply = 1 unit of service.
A6214	Foam dressing, wound cover, sterile, pad size more than 48 square inch., with any size adhesive border, each dressing.
A6233	Gauze, impregnated, hydrogel, for direct wound contact, sterile, pad size more than 48 square inch, each dressing.
A6583	Gradient compression wrap with adjustable straps, below knee, 30-50 mmhg, each.
A6593	Accessory for gradient compression garment or wrap with adjustable straps, not-otherwise specified.
A7025	High frequency chest wall oscillation system vest, replacement for use with patient owned equipment.
E0468	Home ventilator, dual-function respiratory device, also performs additional function of cough stimulation, includes all accessories, components and supplies for all functions.
E0469	Lung expansion airway clearance, continuous high frequency oscillation, and nebulization device.
E0691	Ultraviolet light therapy system, includes bulbs/lamps, timer and eye protection; treatment area 2 square feet or less.
E0743	External lower extremity nerve stimulator for restless legs syndrome, each.
E0762	Transcutaneous electrical joint stimulation device system, includes all accessories.
E1399	Durable medical equipment, miscellaneous.
E2103	Non-adjunctive, non-implanted continuous glucose monitor or receiver.
E2377	Power wheelchair accessory, expandable controller, including all related electronics and mounting hardware, upgrade provided at initial issue.
L1499	Spinal orthosis, not otherwise specified.
L2999	Lower extremity orthoses, not otherwise specified.
L5783	Addition to lower extremity, user adjustable, mechanical, residual limb volume management system.
L5841	Addition, endoskeletal knee-shin system, polycentric, pneumatic swing, and stance phase control.

Items added to this list are eligible to be added to the F2F/WOPD Required List and/or Prior Authorization Required List in the future. The Master List was last updated on May 13, 2024 (89 FR 41324) and currently includes 512 items. The Master list is available on the CMS website.

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