Guides / PPA
PPA Probationary Prior Authorization — new suppliers, 42 CFR 424.527Probationary Prior Authorization for newly enrolled DMEPOS suppliers (Oct 15, 2026)
Citations verified against the CMS Medicare Coverage Database · Reviewed September 2026
Starting October 15, 2026, a DMEPOS supplier that is newly enrolled in Medicare — or that completes a 100% change of ownership on or after that date — enters a one-year provisional period in which 40 specific items require prior authorization, whether or not they are on the Required Prior Authorization List. CMS calls it Probationary Prior Authorization, and it rests on the enhanced-oversight authority for new providers in 42 CFR 424.527.
The codes are orthoses that CMS has identified as higher-risk for fraud, waste and abuse — spinal, knee, ankle-foot, hip and upper limb — plus the two electrical osteogenesis stimulators. If you are a new supplier in these categories, your first year's claims run through the PA process.
The requirements, with citations
Drawn from the CMS program page, the CMS code list, Noridian's program page, and 42 CFR 424.527 — not from AffirmDME's rules engine.
Who is subject
Newly enrolled DMEPOS suppliers, and suppliers undergoing a change of ownership, with the provisional period tied to enrollment on or after October 15, 2026. The regulation's definition of a new supplier also covers 100% ownership changes and reactivated enrollments.
42 CFR 424.527 — provisional period of enhanced oversightOne year from the first claim
The probationary period begins when the supplier submits its first claim for one of the listed items and runs for one year. CMS has published no early-termination mechanism.
CMS — Probationary Prior Authorization ProcessThe 40 codes
Osteogenesis stimulators E0747 and E0748; spinal orthoses L0626–L0630, L0633, L0635, L0641–L0643, L0649, L0720; hip and lower-limb orthoses L1652, L1653, L1686, L1690; knee orthoses L1810, L1812, L1820, L1821; ankle-foot and knee-ankle-foot orthoses L1902, L1906, L1971, L2035, L2132–L2136, L4360, L4361, L4396, L4397; upper limb orthoses L3660, L3670, L3760, L3762, L3809, L3908, L3915, L3960.
CMS DMEPOS Probationary Prior Authorization List — updated September 1, 2026Same process as required PA, alongside it
Submission, review, resubmission and the UTN work exactly as they do for the Required PA List. The probationary process does not replace it — a new supplier billing K0823 or L1833 needs both programs' decisions where they apply.
Noridian — Probationary Prior Authorization programNotification and timing
Suppliers learn they are subject through enrollment letters and welcome packets. The MACs accept requests from October 1, 2026 for dates of service on or after October 15, 2026.
Noridian — Probationary Prior Authorization programWhat usually sinks these claims
- Assuming the Required PA List is the only list — most probationary codes are not on it
- Billing a listed orthosis in the first year without a decision because the item 'never needed PA before'
- Confusing the custom-fitted twins on the probationary list (L3760, L3915) with the off-the-shelf codes on the Required list (L3761, L3916)
- Not knowing when the one-year clock started — it is the first claim for a listed item, not the enrollment date
New supplier? Start with the checklist.
AffirmDME flags probationary and required PA items on the case and builds the packet against the LCD, so a first-year supplier submits the same complete request an established one would. Free in sandbox mode.
Check a case freeFAQ
Which suppliers does probationary prior authorization apply to?
DMEPOS suppliers newly enrolled in Medicare, and suppliers that undergo a change of ownership, on or after October 15, 2026. Established suppliers are not affected unless they change ownership.
How long does it last?
One year, starting from the supplier's first claim for one of the 40 listed items.
Are the codes the same as the Required PA List?
Mostly not. The probationary list is 38 orthotic codes plus E0747 and E0748. A few families overlap by twin code — for example custom-fitted L3760 is probationary while off-the-shelf L3761 is on the Required list — so check each code.
Does it apply to items already covered by required prior authorization?
The two programs run side by side. For an item on the Required PA List you already need a decision; the probationary process adds the 40 codes on top for new suppliers.
Get an email when the Required PA List changes.
CMS adds codes, the DME MACs revise LCDs, cycle deadlines arrive. We send a short note the week it happens, with what to do about it. No drip campaign. Unsubscribe in one click.
This guide summarizes Medicare requirements as implemented in AffirmDME's compliance engine, with citations to the governing sources. It is not legal or billing advice; LCDs and CMS policy change — always confirm against the current policy text linked above.
More guides
- Medicare ADR Letters: how to respond without losing the claim
- Medicare DME Documentation Requirements: the checklist every claim needs
- Medicare CPAP Documentation Requirements (E0601)
- Medicare Home Oxygen Documentation Requirements (E1390)
- Medicare BiPAP / RAD Documentation Requirements (E0470)
- Medicare Hospital Bed Documentation Requirements (E0260)
- Medicare Wheelchair & Power Mobility Prior Authorization (E1161)
- Medicare Knee Orthosis Documentation Requirements (L1833, L1832)
- Medicare TLSO Documentation Requirements (L0456, L0457, L0486)
- Medicare Air-Fluidized Bed Documentation Requirements (E0194)
- Medicare Ultralightweight Manual Wheelchair Requirements (K0005)
- Medicare Upper Limb Orthosis Requirements (L3761, L3916)
- Medicare Osteogenesis Stimulator Documentation Requirements (E0747, E0748)
- The Medicare DMEPOS Required Prior Authorization List, explained (2026)
- The DMEPOS prior authorization exemption: how it works and how to keep it
- Which DME MAC handles your claim: Jurisdictions A, B, C, and D
- Standard Written Order (SWO) requirements for Medicare DME
- Medicare DME face-to-face encounter requirements
- Prior authorization vs ADR vs prepayment review vs TPE: what each means for a DME claim
- After a non-affirmed prior authorization: resubmit, deliver with an ABN, or wait
- Medicare DME proof of delivery requirements
- Preparing and submitting a DMEPOS prior authorization request
Unfamiliar term? The glossary defines ADR, SWO, UTN, PTAN and the rest; the PA List lookup checks any HCPCS code.