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CMS Clarifies Pharmacy Enrollment Pathway Under Nationwide DMEPOS Moratorium
CMS Clarifies Pharmacy Enrollment Pathway Under Nationwide DMEPOS Moratorium
Alexandria, VA — March 2, 2026 —The National Home Infusion Association (NHIA) has received clarification from CMS regarding enrollment options for home infusion pharmacies under the current nationwide DMEPOS enrollment moratorium.
This update provides important guidance for providers seeking to enroll in Medicare while ensuring full compliance with CMS requirements.
Background: DMEPOS Enrollment Moratorium
CMS recently implemented a nationwide enrollment moratorium affecting specific DMEPOS supplier types listed on the CMS-855S enrollment application.
The moratorium applies to the following seven supplier classifications:
- Medical Supply Company
- Medical Supply Company with Orthotics Personnel
- Medical Supply Company with
- Pedorthic Personnel
- Medical Supply Company with Prosthetics Personnel
- Medical Supply Company with
- Prosthetic and Orthotic Personnel
- Medical Supply Company with Registered Pharmacist
While many home infusion pharmacies have enrolled as a “Medical Supply Company with Registered Pharmacist”, other home infusion pharmacies have enrolled under the “Pharmacy” supplier type and are successfully providing the full gamut of covered infusion and nutrition products.
CMS Warning
CMS explicitly warns that attempts to circumvent the moratorium by enrolling under an alternative supplier type could result in denial, revocation, reapplication bars of up to 10 years, or referral to to the Office of Inspector General.
NHIA Outreach to CMS
Given the seriousness of these penalties and the potential implications for beneficiary access to home infusion therapies, NHIA contacted CMS Program Integrity/Provider Enrollment to seek clarification regarding the appropriate enrollment pathway for state-licensed home infusion pharmacies.
Specifically, NHIA asked whether a licensed pharmacy—whose primary business model is pharmacy-based infusion therapy—may appropriately enroll under the “Pharmacy” supplier type on the CMS-855S while furnishing and billing for DMEPOS categories such as:
- External Infusion Pumps
- External Infusion Pump Supplies
- Parenteral Nutrition
- Parenteral Equipment and Supplies
- Intravenous Immune Globulin (IVIG)
- Enteral Nutrition
- Enteral Equipment and Supplies
CMS Response
CMS responded:
“It would be appropriate for a licensed pharmacy to select ‘pharmacy’ as their supplier type on the 855S form. Pharmacies are not subject to the moratorium.”
This clarification confirms that:
- Licensed pharmacies may appropriately select “Pharmacy” as their supplier type on the CMS-855S.
- The Pharmacy supplier type is not subject to the moratorium.
Important Compliance Considerations
While this clarification provides important direction, providers should proceed carefully and ensure:
- The entity is legitimately organized and licensed as a pharmacy under state law.
- The enrollment classification accurately reflects the organization’s operational structure.
- All information provided on the CMS-855S is complete, accurate, and transparent.
- Internal documentation supports the pharmacy-based nature of the business model.
CMS has emphasized close review of applications submitted during the moratorium period. Accurate classification and full disclosure remain critical.
NHIA will continue to update members as additional information becomes available.
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CMS Clarifies Pharmacy Enrollment Pathway Under Nationwide DMEPOS Moratorium
March 3, 2026
The National Home Infusion Association (NHIA) has received clarification from CMS regarding enrollment options for home infusion pharmacies under the current nationwide DMEPOS enrollment moratorium.
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The 2026 government funding for Health and Human Services that passed the House of Representatives today includes a change to the qualifying criteria for drugs under Medicare’s home infusion benefit that may expand access to certain health care provider-administered drugs if an infusion pump is required for administration. Passage of H.R. 4993, the Joe Fiandra Access to Home Infusion Act, reflects Congress’ recognition of the strong patient interest—including among individuals with rare diseases—in home infusion access.
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