The Centers for Medicare & Medicaid Services (CMS) has added 22 HCPCS codes in nine durable medical equipment (DME) categories to the list of products that will require a face-to-face (F2F) encounter and a written order prior to delivery (WOPD) starting Oct. 28.
Treating practitioners are required to document and notify the DME supplier that the practitioner had the face-to-face encounter with the Medicare beneficiary within six months before the date of the WOPD.
The impacted product categories and codes are as follows:
Air Fluidized Bed: E0194
Ankle-Foot Orthosis: L1906, L1933, L1952
Elbow/Wrist Hand Orthosis: L3761, L3916
Home Ventilator: E0466, E0467, E0468
Knee Orthosis: L1833
Manual Wheelchair or Adult Wheelchair: K0002, K0003, K0004, K0005, K0006, K0007, E1161
Oxygen Equipment: K0738
Power Mobility/Power Wheelchair: K0831
Spinal Orthosis: L0456, L0457, L0486
In the Federal Register update (July 30, 2026), CMS tied the codes to “a high rate of fraud or unnecessary utilization” or “high improper payment rates” as listed in Comprehensive Error Rate Testing Medicare Fee-for-Service Supplemental Improper Payment Data reports.
