Health Law Daily Wrap Up, ADMINISTRATION OF MEDICARE/MEDICAID PROGRAMS—FINAL RULES: Medicare Program; Updates to the Master List of Items Potentially Subject to Face-to-Face Encounter and Written OrderPrior to Delivery and/or Prior Authorization Requirements; Updates to the Required Face-to-Face Encounter and Written Order Prior to Delivery List; and Updates to the Required Prior Authorization List, (Jul 31, 2026)

By WK Editorial Staff

This document announces updates to the Healthcare Common Procedure Coding System (HCPCS) codes.

This notice serves to update three separate lists. First, it provides an update to the Master List. Next, this document updates the items included on the Required Face-to-Face Encounter and Written Order Prior to Delivery List. Finally, this document updates items on the Required Prior Authorization List (Final Rule, 91 FR 47972 (July 30, 2026)).

Dates. Implementation of updates to the Master List, the Required Face-to-Face Encounter and Written Order Prior to Delivery List, and the Required Prior Authorization List, excluding upper limb orthoses, are effective October 28, 2026.

Prior authorization requirements for the upper limb orthoses will be implemented in three phases. Phase one includes New York, Michigan, Florida, and California and is effective October 28, 2026. Phase two includes the States in phase one and Pennsylvania, Massachusetts, Ohio, Illinois, Texas, Georgia, Arizona, and Oregon and is effective January 26, 2027. Phase three includes all States and territories not included in phases one and two and is effective April 26, 2027.

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