DMEPOS Enrollment Moratorium: Compliance Risks for O&P Providers

Effective February 27, CMS instituted the DMEPOS enrollment moratorium to manage reports of fraud and abuse within that system. The moratorium had a planned expiration after six months, which as of the date of this writing, has not been extended, although CMS does have the authority to do so at its discretion.

The DMEPOS enrollment moratorium is a temporary regulatory action that halts the enrollment of certain suppliers in Medicare. CMS uses such moratoria as a front-end program integrity tool, shifting post-payment enforcement to preventive controls that stop high-risk entities before they enter the program. Unfortunately, this moratorium is unlikely to result in a reduction in post-payment claims reviews.