CRUSH
CMS just told the whole DMEPOS world, “Prove you’re real.” That’s what this moratorium and fraud crackdown actually mean for honest O&P practices—and your only real proof is complete, timestamped, objective documentation that shows exactly what you did, when, and for whom. CMS is blunt that it is using this moratorium to combat “significant potential for fraud, waste, or abuse after years of troubling trends.”
The Ground Just Shifted (Again) Under DMEPOS
On February 25, CMS implemented a six-month nationwide moratorium on new Medicare enrollment for seven types of DMEPOS medical supply companies, including those with orthotic, prosthetic and/or pedorthic personnel. Any new enrollment or change in majority ownership that falls under those categories is automatically denied during this period. As of 2/26/26, AOPA has received clarification that this moratorium does not apply to enrollees that intend to provide ONLY O, P & P services -- NO DME. However, we would be remiss if we dismiss the initiative. This move is part of a larger “crushing fraud” campaign where CMS has suspended $5.7 billion in payments, denied during this period. This move is part of a larger “crushing fraud” campaign where CMS has suspended $5.7 billion in payments, denied 122,658 claims, and revoked 5,586 providers and suppliers in a single year.
If you’re running a legitimate O&P practice, you may feel like, “We’re not the problem—why are we under the microscope?” The answer is simple: CMS is no longer willing to take anyone’s word for it, and that includes you. In this environment, your documentation has to stand as independent, objective evidence that your care actually happened and meets coverage rules (Crushing Fraud)
Section 1: What CMS Is Really Saying in This Moratorium
CMS’s own language is blunt: the moratorium is aimed at stopping “fraudulent Medicare billing” by certain DMEPOS suppliers and is based on data analysis of high-risk supplier types. They are combining this with aggressive tools—payment suspensions, prepayment reviews, revocations, and referrals to law enforcement—to shut down patterns of suspicious billing.
For legitimate O&P practices, this creates three realities:
You’re operating in a category CMS now labels as high risk by default.
Claims may face more edits, prepay scrutiny, and post-pay review, even if you’ve never had an issue before.
When questions arise, CMS won’t rely on your reputation; they will rely on whatever is—or isn’t—in your chart and your system logs.
This isn’t about scaring you; it’s about recognizing that the bar for “adequate documentation” just went up, whether anyone formally tells you or not.
Section 2: What CMS Actually Looks At
The CMS notice makes it clear that this moratorium and related actions are driven by data analysis, not vibes. They are looking at enrollment volume, supplier type, revocation history, payment suspensions, law enforcement referrals, and complaints to decide where the risk is.
When that lens turns to a specific practice, the questions are very simple:
Do the dates of service line up with when notes were created, edited, and signed?
Is there clear proof of a treating relationship and a valid order?
Is there objective support for medical necessity and proof of delivery.
CMS and OIG case examples in the notice read like a script: braces ordered by telemarketers, supplies shipped without orders, physicians who never saw or spoke to the patient, and millions paid out on claims that had no real clinical backbone. From CMS’s perspective, if your record looks anything like those patterns—thin, generic, late, or disconnected from objective facts—you’re going to have a bad time, no matter how sincere you are.
Section 3: Objective, Contemporaneous Data: Your Real Shield
So, what does “good” look like in this environment? It’s not perfect prose. It’s evidence. For every O&P encounter, your documentation should show clearly and in order:
Contemporaneous entries
Evaluation notes started and signed on the date of service.
Device selection and justification documented before or at the time the order is placed.
Delivery, fitting, and patient instructions documented the day the patient leaves with the device.
Objective data
Measurements, alignment notes, functional level or gait observations, ROM/strength, skin checks, and component choices that match the HCPCS codes you bill.
For supply type items (OTS braces, socks, supplies, compression, etc.), proof of delivery and a valid standard written order where applicable.
Attributable authorship
Who saw the patient, who made which decision, and who signed off—clear in the user's ID and signature trail.
A simple test: if someone neutral, or even adversarial, with no background on your practice, opened your OPIE chart, could they see what you did, why you did it, and that you did it on the day you said you did? If not, your documentation is not yet a shield—it’s a liability.
Section 4: Where AI Fits Into this (And Where It Doesn’t)
You don’t need to make AI the villain here, and CMS doesn’t mention it in the moratorium notice at all. Their concern is not “Did a robot help you write this?” Their concern is, “Did real care actually happen, and can we prove it from your record?”
A reasonable stance for a small O&P practice:
Acceptable uses
Drafting patient-friendly education text.
Helping rephrase explanations of device care or follow-up instructions.
High Risk uses
Generating whole visit notes days later from memory.
Copy pasting the same generic clinical narrative across multiple patients.
Doing any part of documentation outside the EMR and then backfilling just enough into the system to get a claim out the door.
The problem is not the AI tool; it’s over relying on any tool that replaces real-time entry of real clinical facts in your EMR. CMS can’t see what you did in Word, email, or a chatbot window. They only see what’s in your electronic record and its metadata: timestamps, user IDs, and event history.
OPIE Anywhere was built for exactly this kind of scrutiny. It doesn’t just hold notes; it captures the timeline of your work from referral through delivery and follow-up.
Used as designed, an OPIE workflow naturally creates what CMS wants to see:
Timestamped events for scheduling, check-in, evaluation, fabrication steps, delivery, and follow-ups.
Structured clinical processes and required fields that push clinicians to document medical necessity elements, objective measurements, and device details up front—not as an afterthought.
Role based access and signatures so it’s clear who entered what and when, and when a note was finalized.
If CMS or a payer ever questions a claim, you want to be able to pull up a single patient’s record and show a coherent story: the referral, the evaluation and measurements on a specific date, the order, the delivery with proof and instructions, and any follow-up encounters. That’s the opposite of the “ghost supplier” scenarios CMS and OIG describe, where beneficiaries never saw anyone and still got billed.
Section 5: What Practice Leaders Should Do This Month
You don’t need a multi-year project plan. You do need to tighten a few screws—deliberately and quickly—while CMS is signaling where it’s headed.
Here’s a simple one week playbook:
Set a same day rule: all patient encounters must be documented and signed by the treating clinician on the date of service, inside your system—not in Word, not in email.
Clarify your AI policy: it’s fine to brainstorm phrasing, but prohibit any use of AI that replaces point-of-care documentation or obscures who actually performed the service. (The Quality Outcomes P&P Manual covers this now)
Run an internal spot audit: pull 10–15 recent Medicare encounters and ask, “If CMS saw only this record, would they be satisfied we really did this work?”
Train to the workflow: make sure clinicians, admins, and billers all understand how scheduling, notes, coding, and delivery documentation hang together to tell one consistent story. Use a lunchtime huddle, not a marathon meeting.
You’ve worked too hard to build a reputable O&P practice to get lumped in with “high risk suppliers” just because your documentation looks thin or artificially polished. In a world where CMS is suspending billions and revoking thousands of providers, your best defense is simple: document what you actually did, when you actually did it, in a system that can help you prove it.