The document at the center of this change is an ordinary one: a signed written order that has to reach the equipment supplier before the item is delivered, supported by a face-to-face visit with the treating practitioner in the six months before that order was written. On October 28, 2026, twenty-two more equipment codes come under that requirement. The notice setting the date runs seven pages in the Federal Register, and it names every code it touches.
Twenty-two codes join the face-to-face and written-order list
Eight of the additions are wheelchairs, and they cover the ordinary end of the category rather than exotic equipment. The standard hemi low-seat chair, the lightweight chair, the high-strength lightweight chair, the ultralightweight chair, the heavy-duty chair and the extra-heavy-duty chair are all on the list, along with a manual adult tilt-in-space chair and a group 2 standard power wheelchair with a seat elevator.
The rest divides into equipment a household would recognize on sight. Three home ventilator codes are added, including the multi-function device that also handles oxygen concentration, nebulization, aspiration and cough stimulation. One oxygen code covers a rental portable gaseous system with its containers, regulator, flowmeter, humidifier, cannula and tubing. An air fluidized bed is added. The remaining nine are braces: three thoracic-lumbar-sacral orthoses, a knee orthosis with adjustable joints, three ankle-foot orthoses, an elbow orthosis with a locking joint, and a wrist-hand orthosis. The notice publishing all three list updates appeared July 30, 2026.
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Eight of those codes also require prior authorization
A written order is the lighter requirement. Prior authorization is the heavier one, because it means a request has to be submitted and reviewed before the item is handed over and before the claim is filed. Eight codes are being added to that list: the air fluidized bed, the ultralightweight wheelchair, the adjustable-joint knee orthosis, the three thoracic-lumbar-sacral orthoses, the elbow orthosis and the wrist-hand orthosis.
The submission itself is not a formality. It has to include the written order or prescription, relevant information from the beneficiary’s medical record, and supplier-produced documentation showing the item meets Medicare coverage, coding and payment rules. A reviewer then returns a decision that either provisionally affirms or does not affirm the request. The 74 codes already subject to prior authorization continue without interruption, and the updated list is posted on the CMS page that carries both the master list and the prior authorization list.
Upper limb braces phase in by state through April 2027
Two of the eight prior-authorization additions, the elbow orthosis and the wrist-hand orthosis, do not go nationwide at once. CMS split them into three phases, and the first covers four states, one in each equipment jurisdiction: New York, Michigan, Florida and California, beginning October 28, 2026.
Phase two adds Pennsylvania, Massachusetts, Ohio, Illinois, Texas, Georgia, Arizona and Oregon on January 26, 2027. Phase three extends the requirement to every remaining state and territory on April 26, 2027. The stated reason is volume control: smaller claim counts in the first two phases give the agency a chance to find and fix problems before the requirement reaches everyone. The face-to-face and written-order requirements for those same two codes are not phased, and take effect for all states on October 28.
Improper payment rates between 22 and 48 percent drove the selection
CMS explains its choices with error data rather than anecdote. Its Comprehensive Error Rate Testing program found improper payment rates from 2023 through 2025 running roughly 40 to 48 percent for upper limb orthoses and 35 to 47 percent for lower limb orthoses. For manual wheelchairs the range was 22.1 to 42 percent over the same period. Lumbar-sacral orthoses, ventilators, oxygen equipment and hospital bed accessories all appeared among the top 20 equipment categories for improper payments in 2025.
The notice also cites the agency’s Fraud Defense Operations Center, which has reported more than $1.5 billion in payments suspended for equipment items tied to suspected fraudulent billing, and points to Justice Department cases involving medically unnecessary equipment and telemarketing arrangements aimed at Medicare beneficiaries. CMS estimates net savings of $15.8 million from the prior-authorization additions after implementation costs, which is why the notice is classified as not economically significant.
The master list behind all of it grows by 20 codes
Underneath the two active lists sits a third: a library of items flagged as vulnerable, from which the agency selects what to actually regulate. It stood at 530 items, gains 20 codes in this notice, and loses none. Eight of the twenty were added for aberrant billing, meaning suppliers submitted at least 1,000 claims and received at least $1 million between July 2024 and June 2025, with payments rising more than 30 percent over the prior twelve months and no explanation the agency could identify.
Being on the master list does not by itself impose anything. Only items selected and announced through a Federal Register notice carry the conditions of payment, which is the step this notice performs. After it takes effect, 105 codes will require a face-to-face encounter and a written order before delivery, up from the 83 shown on the list CMS maintains for that requirement after its last update in January 2026. Forty-six of those 83 are power mobility devices that Congress placed there by statute.
This article was produced with AI assistance and reviewed by a human editor. Figures are linked to their primary sources; where a claim could not be verified from the public record, we say so.
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