How the Medicare DMEPOS Master List Update Impacts SLPs

June 27, 2024

The Centers for Medicare & Medicaid Services (CMS) recently released updates to the master list of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) items potentially subject to additional conditions of payment.

CMS has added the following Healthcare Common Procedure Coding System (HCPCS) codes to the master list:

E0482: Cough stimulating device, alternating positive and negative airway pressure
E0490: Power source and control electronics unit for oral device/appliance for neuromuscular electrical stimulation of the tongue muscle, controlled by hardware remote
E2510: Speech generating device (SGD), synthesized speech, permitting multiple methods of message formulation and multiple methods of device access.

This marks the first time an SGD has been placed on the master list since it went into effect in 2020. E2510 is currently the only SGD on the list. The updated list will go into effect August 12, 2024.

What This Means for Speech-Language Pathologists (SLPs)

Items added to the master list have been flagged as potential vulnerabilities to the Medicare program due to various factors. Inclusion on the master list does not mean there is an automatic change in coverage or payment requirements for those specific items. Clinicians don’t need to take any additional action unless an item on the master list also appears on one or both of the following lists: the required prior authorization list [PDF] and the required face-to-face and written order prior to delivery list [PDF].

In this case, the three codes listed above have not been added to either of those two lists. That means that SLPs should continue to follow standing coverage and documentation requirements, including ensuring there is a written order for any piece of durable medical equipment (DME), including an SGD, on file from the treating practitioner (physician, physician assistant, nurse practitioner, or clinical nurse specialist). The written order does not need to be submitted prior to delivery of the DME item, but it must be on file and available on request by CMS or the DME contractor.

See CMS’s resource for more information on the master list and items potentially subject to conditions of payment.

What Is the Master List?

The master list serves as a library of items and HCPCS codes that have been identified as potential vulnerabilities to the Medicare Trust Fund due to their potential cost and potential for high utilization. CMS uses the following criteria to identify items to add to the master list:

The average purchase fee is $500 or greater
The average monthly rental fee schedule is $50 or greater
Items account for at least 1.5% of Medicare expenditures for all DMEPOS
Any items with at least 1,000 claims and $1 million in payment during the most recent 12-month period
Any items statutorily requiring a F2F/WOPD or prior authorization.

This master list is updated at least annually or more frequently as needed and is adjusted for inflation.

What’s Next

Because these requirements are written into law, CMS is required to implement these changes based on the criteria established by Congress. Although the most recent updates don’t impact conditions of payment for SGDs or other speech-language pathology related items, SLPs should continue to check for updates in case CMS adds one or more items to the required prior authorization or face-to-face and written order prior to delivery lists.