CMS Updates Medicare Face-to-Face, Written Order and Prior Authorization Item Lists
CMS published a rule on July 30, 2026 updating HCPCS codes on three Medicare item lists tied to face-to-face encounter, written order and prior authorization requirements.
On July 30, 2026, the Centers for Medicare & Medicaid Services (CMS), part of the Department of Health and Human Services, published a rule in the Federal Register as document 2026-15446 [1]. It updates three lists of Medicare items connected to face-to-face encounter, written order and prior authorization requirements [1]. The published summary is brief, so this piece covers only what that summary establishes and what a practice can check against the lists [1].
What the rule does
The rule announces updates to the codes on three lists [1]. The codes come from the Healthcare Common Procedure Coding System (HCPCS), the coding system used to identify the items on each list [1]. The three lists are:
- The Master List of Items Potentially Subject to Face-to-Face Encounter and Written Order Prior to Delivery and/or Prior Authorization Requirements [1].
- The Required Face-to-Face Encounter and Written Order Prior to Delivery List [1].
- The Required Prior Authorization List [1].
The list names distinguish between items that are potentially subject to these requirements, on the Master List, and items for which a face-to-face encounter and a written order before delivery, or prior authorization, are required [1].
Who it affects
The summary does not name affected parties; it identifies the document as a Medicare Program rule that updates HCPCS codes on the three lists [1].
Dates that matter
The rule was published on July 30, 2026, and the Federal Register classifies it as a rule rather than a proposed rule [1]. The summary does not state an effective date or an implementation date for the updated codes [1]. By contrast, two other CMS documents from the same month are proposals: the calendar year (CY) 2027 Physician Fee Schedule proposed rule, published July 16, 2026, and the CY 2027 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center proposed rule, published July 7, 2026 [2][3].
Related prior authorization activity
The CY 2027 hospital outpatient and ambulatory surgical center proposed rule separately proposes to expand the prior authorization requirement to include additional botulinum toxin injection services [3]. That proposal is distinct from the item lists updated in document 2026-15446 and remains a proposal rather than a final policy [1][3].
What a practice should check
- Retrieve the full text of document 2026-15446 from the Federal Register, since the summary does not reproduce the code-level changes [1].
- Build a short inventory of the HCPCS codes your clinicians order for Medicare patients and compare it against the updated Master List [1].
- Compare the same inventory against the Required Face-to-Face Encounter and Written Order Prior to Delivery List and the Required Prior Authorization List, flagging any code whose status has changed [1].
- For any code on the face-to-face and written order list, review scheduling and ordering steps so that the encounter and the written order are in place before delivery, as the list name indicates [1].
- For any code on the prior authorization list, note that the list name indicates prior authorization is required for that item [1].
- If your clinicians provide botulinum toxin injections in hospital outpatient settings, track the proposed prior authorization expansion separately, because it is still at the proposal stage [3].
Limitations
The published summary of document 2026-15446 does not state which HCPCS codes were added or removed, how many changed, when the changes take effect, who is affected, or CMS's reasons for the updates [1]. This brief therefore describes the structure and scope of the update rather than its code-level content, and it does not assess whether any particular item ordered by a given practice is affected [1].
References
- federalregister.gov. Medicare Program; Updates to the Master List of Items Potentially Subject to Face-to-Face Encounter and Written Order Prior 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. Accessed October 8, 2026. federalregister.gov
- federalregister.gov. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program. Accessed October 8, 2026. federalregister.gov
- federalregister.gov. Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; and Quality Reporting Programs; Including the Hospital Outpatient Quality Reporting Program and Ambulatory Surgical Center Quality Program; Request for Information on Strengthening the Standardization and Comparability of Hospital Price Transparency (HPT) Data; Prior Authorization; Accrediting Organization (AO) Deeming for Emergency Medical Treatment and Labor Act (EMTALA); and Notices of Closure of Teaching Hospitals and Opportunities To Apply for Available Slots. Accessed October 8, 2026. federalregister.gov
How this was written: drafted with AI from the sources listed above, then checked automatically, claim by claim, against them before publishing. The SmartMeet Desk writes about scheduling, video visits, productivity, time management and running a care team, and the privacy rules around them, from public guidance and published research. Every factual statement links to its source.