The Compliance Monitor (9/30/26)
Your source for federal updates
September/October 2026 Compliance Activity
| Compliance Item & Date | Additional info & Links |
| CMS DMEPOS Enrollment Moratorium Expired Aug 27, 2026 | The six-month nationwide Medicare enrollment moratorium on certain DMEPOS supplier types has expired, and enrollment applications are once again being accepted. The moratorium was implemented by CMS in February 2026 as part of ongoing efforts to address fraud, waste, and abuse within the DMEPOS supplier community. Read the CHAP blog for additional information. |
| Submit Comments on the CY 2027 PFS Proposed Rule Policy for Quality Payment Program The palliative care RFI in the CY 2027 Medicare Physician Fee Schedule Proposed Rule asks for stakeholder input on how Medicare might improve coding, payment, and access for palliative care services outside of hospice. It is not a proposal to create a new benefit yet; it is CMS asking questions to inform possible future policy. Sep 14, 2026 | The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP). |
| DMEPOS: Probationary Prior Authorization Starts October 15, 2026 | Effective October 15, 2026, CMS will: – Implement a nationwide 1-year probationary prior authorization (PPA) process for newly enrolled suppliers and suppliers undergoing a change of ownership – Require prior authorization as a condition of payment for certain DMEPOS items (PDF) with dates of services on or after October 15 New and change of ownership suppliers are also subject to regular program oversight initiatives, including the following requirements: – Required prior authorization – Face-to-face encounter – Written order prior to delivery More Information: – PPA Process for Newly Enrolled Suppliers of Certain DMEPOS Items webpage – Prior Authorization Process for Certain DMEPOS Items webpage – DMEPOS Order & Face-to-Face Encounter Requirements webpage – MLN Matters® Article SE20007 (PDF) |
| PEPPER webinar – Home Health September 24, 2026, 1:00 p.m. ET: Register today. | PEPPER for Home Health Agencies is available via the PEPPER Portal at https://pepper-file.cbrpepper.org. Current PEPPER User Guide: – Home Health Agencies PEPPER User Guide (PDF, CY 2025 Release, August 2026) Demonstration PEPPER: – Demonstration PEPPER version CY 2025 (XLSX) |
| FY 2027 Hospice Payment Update final rule effective Oct 1, 2026 | Provisions of this rule are effective |
| CMS Home Health Payment Update Rule (Final) Annual CY issuance Usually posted in late October – early November | Will first appear on the Federal Register Public Inspection Desk https://www.federalregister.gov/pu blic-inspection/current Will move over to the Federal Register within a few days of initial posting https://www.federalregister.gov/do cuments/current |
| CMS HHQRP non-compliance letters – Providers will receive a letter if they are found not in compliance with quality reporting requirements – Providers may submit a request for reconsideration to CMS if they do not agree with the CMS outcome Non-compliance notifications will be distributed by the Medicare Administrative Contractors (MACs) and will be placed into provider CASPER folders in iQIES Usually distributed in October | Instructions for appeal are included in the notification and on the Home Health Quality Reporting Reconsideration and Exception & Extension webpage |
| Medicare Care Compare Refresh Home health quality scores are publicly reported on the Care Compare website and updated on a quarterly basis. October 2026 | Medicare Care Compare https://www.medicare.gov/care-compare/ Information about home health public reporting dates https://www.cms.gov/medicare/quality/home-health/home-health-quality-reporting-data-submission-deadlines |
Top Items
CMS Refocuses Medicaid Quality on Health Outcomes, Launches Innovative Partnership With 37 States
CMS announced a new partnership with 37 states to shift Medicaid and CHIP quality programs away from process and paperwork measures and toward actual health outcomes, particularly in prevention, chronic disease management, and behavioral health. CMS also aims to reduce reporting burden, expand digital quality measurement, and better align financial accountability with outcomes. The initiative, called Investing in Health Outcomes, is built around a voluntary Medicaid Quality Pledge that participating states will use to guide future quality improvement efforts.
This signals CMS’s growing emphasis on outcome-based care, streamlined quality reporting, and value-based accountability, trends that may influence future Medicare, Medicaid, home health, and hospice quality programs.
The Medicaid Quality Pledge and additional information around the Investing in Health Outcomes effort are available online. CMS will also hold workshops later this year focused on measure prioritization and value-based arrangements, reduced reporting burden, and digital quality measurement.
For more information and to participate in the Medicaid Quality Pledge, visit: www.medicaid.gov/medicaid/quality-of-care/investing-health-outcomes.
Fraud and Abuse Update
Medicare Advantage Organizations and CMS Can Do More To Prevent Durable Medical Equipment Fraud in Medicare Advantage (OEI-02-24-00310)
HHS-OIG’s new issue brief reveals that screening gaps leave Medicare Advantage (MA) vulnerable to fraudulent Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) billing. Unlike Original Medicare, CMS does not require all DMEPOS suppliers billing MA to be enrolled in Medicare, allowing bad actors to skip background checks and site visits. OIG found that out-of-network, non-enrolled suppliers billed seven times more per enrollee for orthotics than other suppliers. OIG recommends that CMS require Medicare enrollment for all DMEPOS suppliers billing MA and strengthen out-of-network checks.
CMS Cracks Down on Fraud, Waste, and Abuse in the Federal Health Insurance Marketplace
As part of the ongoing efforts of the White House Task Force to Eliminate Fraud to crush fraud in the healthcare system and protect taxpayer dollars, the Centers for Medicare & Medicaid Services (CMS) is taking aggressive, sweeping actions within the Federal Marketplace — canceling approximately 315,000 unauthorized enrollments covering more than 760,000 individuals, which is expected to result in a return of roughly $2.2 billion in taxpayer-funded subsidies.
CMS has established a Federally-facilitated Exchange (FFE) anti-fraud coordination group that brings together leadership from across CMS and the U.S. Department of Health and Human Services (HHS) to drive a unified, sustained response to fraud in the Federal Marketplace. The group will meet regularly to coordinate enforcement and program integrity efforts and maintain momentum in the fight to crush fraud in the FFE.
For more information about Marketplace Anti-Fraud actions, visit: https://www.cms.gov/newsroom/fact-sheets/federal-marketplace-ffe-sbe-fp-anti-fraud-actions.
Hospice Care Provider Updates
NEW RESOURCE AVAILABLE: Hospice Quality Reporting Program (HQRP) Data Submission and Provider Reports web-based training
The Centers for Medicare & Medicaid Services (CMS) is providing the second part of a two-part series on the Hospice Quality Reporting Program (HQRP) data submission requirements and reports. This training provides guidance on HOPE data submission and related iQIES provider reports.
This web-based training can be accessed through the Hospice Quality Reporting Training and Education Library webpage.
If you have questions about accessing this resource, please email the PAC Training Mailbox. Content-related questions should be submitted to HospiceQualityQuestions@cms.hhs.gov.
DMEPOS/Supplier Updates
Toileting Aids: Prevent Claim Denials
In 2024, the improper payment rate for commodes, bed pans, and urinals was 32.6%, with a projected improper payment amount of $2.5 million. Learn how to bill correctly for these services. Review the Toileting Aids provider compliance tip for more information, including:
- Denial reasons and how to prevent them
- Documentation requirements
CMS Cracks Down on Fraud, Waste, and Abuse in the Federal Health Insurance Marketplace®
As part of the ongoing efforts of the White House Task Force to Eliminate Fraud to crush fraud in the healthcare system and protect taxpayer dollars, the Centers for Medicare & Medicaid Services (CMS) is taking aggressive, sweeping actions within the Federal Marketplace — canceling approximately 315,000 unauthorized enrollments covering more than 760,000 individuals, which is expected to result in a return of roughly $2.2 billion in taxpayer-funded subsidies.
CMS has established a Federally-facilitated Exchange (FFE) anti-fraud coordination group that brings together leadership from across CMS and the U.S. Department of Health and Human Services (HHS) to drive a unified, sustained response to fraud in the Federal Marketplace. The group will meet regularly to coordinate enforcement and program integrity efforts and maintain momentum in the fight to crush fraud in the FFE.
“We are shutting down unauthorized Marketplace enrollments and returning approximately $2.2 billion in taxpayer-funded subsidies,” said HHS Secretary Robert F. Kennedy, Jr. “CMS is strengthening safeguards, pursuing bad actors, and holding agents and brokers accountable when they break the rules. Under President Trump, HHS will protect Americans’ health coverage and ensure taxpayer dollars reach the people they are intended to serve.”
These actions are part of CMS’ three-pronged strategy to prevent fraudulent and improper enrollments, remove existing unauthorized enrollments, and strengthen oversight and enforcement of agents and brokers participating in Exchanges.
“Every dollar lost to fraud is a dollar taken from hardworking taxpayers and the Americans these programs are intended to serve,” said CMS Administrator Dr. Mehmet Oz. “We are using our data, enforcement authorities, and stronger safeguards to identify fraud and abuse, stop it, and recover taxpayer dollars. We are making sure Americans — not bad actors — remain in control of their health coverage.”
CMS will continue working with health insurance companies to identify and investigate potentially unauthorized enrollments, cancel those confirmed to be unauthorized, and recoup and end associated taxpayer-funded subsidies.
The agency is also holding agents and brokers accountable for violating Marketplace standards. Since January 2026, CMS has issued termination notices for over 200 non-compliant agents and brokers. This summer, CMS issued 569 notices of intent to terminate to those agents and brokers who submitted 2026 applications without key applicant information, such as Social Security Numbers (SSN).
CMS data also show that agents and brokers who first registered for the 2026 plan year represent a small fraction of all agent- and broker-assisted enrollments but account for a disproportionate share of unauthorized enrollments and other high-risk activity in the Marketplace. To address this risk, CMS is releasing an Interim Final Rule announcing a temporary moratorium on new registration for the 2027 plan year for agents and brokers without an active Exchange Agreement for 2026.
CMS is also strengthening program integrity protections by:
- Requiring all existing agents and brokers to re-identity proof through Login.gov or ID.me;
- Requiring applications involving an agent or broker to include SSN or immigration document numbers that CMS can verify for all non-newborn applicants through all application channels;
- Updating the system to prevent agents and brokers from being added to applications that consumers should be completing on their own through HealthCare.gov; and
- Requiring electronic consumer authorization before an agent or broker can act on a consumer’s application or enrollment.
Taken together, these measures strengthen Marketplace integrity, hold bad actors accountable, and better protect consumers and taxpayers from unauthorized activity.
For more information about Marketplace Anti-Fraud actions, visit: https://www.cms.gov/newsroom/fact-sheets/federal-marketplace-ffe-sbe-fp-anti-fraud-actions
All Providers Updates
HHS Launches First Ever Department-Wide PPE Demand Forecast to Strengthen American Manufacturing
The U.S. Department of Health and Human Services (HHS) has launched its first department-wide Personal Protective Equipment (PPE) Forecast, establishing a recurring process that requires all HHS divisions to identify, maintain, and update anticipated PPE purchasing needs on a quarterly basis. The initiative is designed to provide American manufacturers with greater visibility into future federal demand, helping them make informed decisions about workforce, production capacity, and investments while strengthening domestic supply chains and emergency preparedness. Forecasts will include known and anticipated PPE purchases acquired through all authorized purchasing methods, and consolidated information will be published through HHS’s Small Business Customer Experience (SBCX) platform to support industry awareness and competition opportunities. The policy implements the Make PPE in America Act and aims to improve acquisition planning, reduce supply chain risks, and support U.S. manufacturing.
BPCI Advanced Final Evaluation Shows $800M in Net Savings
Summary
The CMS Innovation Center released the final evaluation of the Bundled Payments for Care Improvement Advanced (BPCI Advanced) model, finding that it generated more than $800 million in net Medicare savings over eight model years while maintaining positive patient care experiences. The evaluation demonstrated that episode-based financial accountability can reduce Medicare spending, improve awareness of post-acute care quality and costs, and support better discharge planning and recovery outcomes. Although CMS determined the model did not meet criteria for expansion, lessons learned have been incorporated into the Transforming Episode Accountability Model (TEAM), which launched on January 1, 2026, to further reduce avoidable emergency department visits and hospital readmissions. Participants, including hospitals and physician group practices, achieved approximately $700 to $1,100 in spending reductions per episode.
CMS Adds Medicare Options to Help People Manage Substance Use Disorder, Heart Failure & Other Common Chronic Conditions
Starting in Spring 2027, CMS will expand an existing initiative to offer technology-supported care options to Medicare beneficiaries who have heart failure, chronic obstructive pulmonary disease, substance use disorders, and nicotine dependence. With these additions, CMS will enable more people with common chronic conditions and Original Medicare to receive ongoing care, designed to help them improve their health and stay independent, from the comfort of their homes.
This disease management support is made possible by the Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model. The model supports CMS’s work on modernizing the nation’s digital health ecosystem and empowering Medicare beneficiaries through greater access to innovative health technologies. ACCESS uses a new payment approach that emphasizes achieving specified health outcomes. Instead of paying solely for individual services, CMS ties payments directly to measurable improvements in patient health.
CMS is maintaining a directory at Medicare.gov/ACCESS of participating organizations and covered conditions in the ACCESS Model to help patients and providers evaluate their options.
Read the full press release.
Educational Opportunities
CMS National Provider Enrollment Conference – November 18 & 19
Wednesday, November 18 & Thursday, November 19 in Orlando, Florida
Meet with provider enrollment experts from CMS, Medicare Administrative Contractors, and DME National Provider Enrollment Contractors. Visit the 2026 CMS National Provider Enrollment Conference webpage for more information. Registration opens in mid-September.
OIG Workplan
HHS-OIG’s Work Plan sets forth various projects including audits and evaluations that are underway or planned to be addressed during the fiscal year and beyond. The work planning process is dynamic and adjustments are made throughout the year to meet priorities and to anticipate and respond to emerging issues with the resources available.
Review active action items on the Office of the Inspector General’s Work Plan by provider type.
Resources
New Health IT Resource Available – Introducing Cartos
Introducing Cartos – ONC’s public, FHIR-enabled terminology service that helps implementers find, understand, and use terminology content connected to ONC regulations and the Standards Version Advancement Process. It allows users to find up-to-date and correct terminology assets by bringing regulatory context, implementation guide references, terminology metadata, and terminology content together in one coordinated location.