Trump Administration Announces Nationwide DMEPOS Enrollment Moratorium

Published in Government Relations on February 26, 2026

Original article by The van Halem Group

In a press release published on the CMS website February 25, 2026, it was announced that CMS will implement a six-month moratorium on new enrollments for DMEPOS suppliers. Click here to view a list of FAQs below.

With a suspected immediate effective date, no new DMEPOS suppliers of the following seven types (as well as no new practice locations of these seven types) will be enrolled into Medicare unless the supplier’s enrollment application was received by the applicable Medicare contractor prior to the effective date.

The moratorium applies to suppliers of these seven types seeking to enroll anywhere in the United States, including all states, territories, and the District of Columbia. The seven supplier types are as follows:

• 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
• Medical supply company with respiratory therapist

A medical supply company is considered a business whose principal function is to furnish DMEPOS supplies (regardless of supply type) directly to another party, such as, but not limited to: (1) beneficiaries with a medical order (for example, via mail order); (2) medical providers and suppliers; or (3) both.

CMS will very closely screen all DMEPOS supplier applications submitted during the moratorium to ensure that the supplier is not a medical supply company (including site visits and online research of the business).

This announcement comes on the heels of the Final Rule, which introduced the newest round of competitive bidding, annual accreditation, and rules surrounding changes in majority ownership (CIMO). More specifically, the Final Rule introduced a “36-month rule” for DMEPOS suppliers that limits the transfer or use of Medicare billing privileges after a “change in majority ownership.” This is defined as an acquisition of more than a 50% direct ownership interest (including in an asset sale, stock transfer, merger, or consolidation), which can happen in a single transaction or through multiple smaller deals that add up to over 50% within a 36-month period. If a change in majority ownership happens within 36 months of the supplier’s initial Medicare enrollment or its most recent ownership change, the billing privileges will not be transferred to or inherited by the new owner.

Instead, the buyer must enroll as a new supplier and get a new accreditation, unless a specific exception applies. These exceptions are:

1. Internal corporate restructurings at the parent level (such as a merger or consolidation);
2. Changes in the DMEPOS supplier’s business structure where the owners remain the same (for example, converting from a corporation to a partnership or LLC); and
3. The death of an individual owner.

How does the moratorium come into play with the 36-month rule?

According to CMS, if a DMEPOS supplier undergoes a non-exempt change in majority ownership (CIMO) within 36 months of its initial enrollment (or within 36 months of its most recent CIMO), the supplier must enroll in Medicare as a brand new supplier, undergo a survey, and become newly accredited. The supplier’s current enrollment is terminated. This means that the supplier’s new enrollment is an initial enrollment no less than if the supplier had never enrolled in Medicare before.

This means that this moratorium would prohibit the supplier in this § 424.551 situation from re-enrolling in Medicare because it would constitute an initial enrollment; the supplier is “new.”

CMS can deny the enrollment application of a provider or supplier if the provider or supplier is subject to a moratorium under § 424.530(a)(10) and 424.570(c).

CMS has the authority to:

• Deny enrollment and impose a reapplication bar of up to 10 years for a provider’s or supplier’s submission of false or misleading information on (or omission of information from) the enrollment application in order to gain enrollment in the Medicare program.
• Revoke a provider’s enrollment for the submission of false or misleading information under § 424.535(a) and can impose a reenrollment bar of up to 10 years.

This is developing information; however, we will continue to post updates as we learn more.

Did You Know? 

Did you know that The van Halem Group has an enrollment expert available to assist you with your enrollment needs? Their enrollment support services include assistance with updates and changes to your enrollment record, completing a new enrollment application, or assisting with PTAN deactivations and revocations. Contact The van Halem Group today to learn how they can help you maintain enrollment compliance! 

FAQs - DMEPOS Moratorium on Enrollment

1. What supplier types are affected by the six-month moratorium?
        a. Medical supply company
        b. Medical supply company with orthotics personnel
        c. Medical supply company with pedorthic personnel
        d. Medical supply company with prosthetics personnel
        e. Medical supply company with prosthetic and orthotic personnel
        f. Medical supply company with registered pharmacist
        g. Medical supply company with respiratory therapist
2. If I currently have an enrolled location, can I open a second location under the same TIN?
        a. If the supplier is one of the seven “medical supply company” types listed above, no. The moratorium applies to new practice locations.
3. What happens if I have an application currently pending with the NPE?
        a. Enrollment applications that were received by the applicable Medicare contractor prior to the notice’s effective date will continue to be processed.
4. What will happen to my application if it is submitted after the effective date of the notice?
        a. CMS can deny the enrollment application of a provider or supplier if the provider or supplier is subject to a moratorium under § 424.530(a)(10) and 424.570(c).
5. How do I know if I qualify under one of the seven supplier types?
        a. A medical supply company is considered a business whose principal function is to furnish DMEPOS supplies (regardless of supply type) directly to another party, such as, but not limited to: (1) beneficiaries with a medical order (for example, via mail order); (2) medical providers and suppliers; or (3) both.
6. I am a physician enrolling my practice to provide DMEPOS to my patients. Will my application be denied?
        a. Pharmacies, physicians, hospitals, physical therapists, and other DMEPOS supplier types will remain able to open new practice locations throughout the country.
7. Our DME company recently experienced a majority ownership change. How will this affect my enrollment?
        a. If a DMEPOS supplier undergoes a non-exempt change in majority ownership on or after January 1, 2026:
   
               i. The supplier must enroll in Medicare as a brand-new supplier, undergo a survey, and become newly accredited.
   
               ii. The supplier’s current enrollment is terminated.
   
         This means that the supplier’s new enrollment is an initial enrollment no less than if the supplier had never enrolled in Medicare before. This means that this moratorium would prohibit the supplier from re-enrolling in Medicare because it would constitute an initial enrollment; the supplier is “new.”
8. What qualifies as an exemption to the new changes in majority ownership reporting requirement?
         a. The 36-month rule does not apply to “indirect” ownership changes, nor does it apply to the following changes:
     
                i. A DMEPOS supplier's parent company is undergoing an internal corporate restructuring, such as a merger or consolidation.
   
                ii. The owners of the existing DMEPOS supplier are changing the DMEPOS supplier's current business structure (for example, from a corporation to a partnership (general or limited); from a limited liability company (LLC) to a corporation; or from a general or limited to an LLC) and the owners remain the same.
   
                iii. An individual owner of the DMEPOS supplier dies.
9. I submitted my application for enrollment after the effective date and paid the application fee. What happens if my application is denied?
         a. Per § 424.514(d)(2)(v)(C)), if the provider or supplier was required to pay an application fee, the fee will be refunded if the application is denied because of the imposition of a moratorium.
10. What changes would not be applicable under the moratorium?
          a. Under § 424.570(a)(1)(iii), a temporary moratorium does not apply to any of the following        

                        i. Changes in practice location (except if the location is changing from a location outside the moratorium area to a location inside the moratorium area).

                        ii. Changes in provider or supplier information, such as phone number or address.

                        iii. Changes in ownership (except changes in ownership of home health agencies that would require an initial enrollment).

                        iv. Also, in accordance with §424.570(a)(1)(iv), a temporary moratorium does not apply to any enrollment application that has been received by the Medicare contractor prior to the date the moratorium is imposed.

We will continue to monitor this announcement and its impact on our industry. Updates will be posted to the blog, and we will continue to add to the FAQs. If you have questions or want some assistance with your enrollment, contact The van Halem Group today!