By: Mario S. Turner

DMHC’s March 2026 Roundtable Signals a Busy Year Ahead

The Department of Managed Health Care (DMHC) held its quarterly roundtable on March 4, 2026, and the message was clear: 2026 will be an active year for health plans. DMHC shared updates on assessments, pending regulations, licensure initiatives, network reporting, and several recently enacted laws. While some items remain in development, the Department’s comments offered a useful look at where regulatory attention is headed.

Assessments, Budget Proposals, and Oversight Priorities

DMHC explained that it does not yet know the 2026-27 health plan assessment rate, though it expects enrollment changes at the federal level may affect the per-enrollee amount. The Department said its annual assessment APL should be issued within the next four to six weeks. DMHC also discussed proposed trailer bill language related to menopause services, including a public education campaign and additional staffing. Beyond those proposals, DMHC raised concerns it has recently seen in-network participation and continuity of care, including reports that some plans may be declining to contract with certain DHCS-provisionally licensed residential treatment centers and concerns about transitions from out-of-network to in-network behavioral health providers without adequate analysis of clinical appropriateness.

Regulatory Activity Continues to Expand

DMHC’s Office of Legal Services reported progress on several regulations. The provider directory regulations under SB 137 have now been approved and will take effect on April 1, 2026. DMHC also announced that formal rulemaking for the SB 17 prescription drug reporting regulations is beginning, with the package submitted to the Office of Administrative Law. In addition, DMHC said it is moving forward with regulations related to health equity and quality standards under AB 133, and it is again seeking stakeholder feedback on proposed revisions to its general licensure regulation, including the exemption process for entities accepting global risk. At the same time, the Department acknowledged continued uncertainty around its proposed Essential Health Benefits benchmark update after CMS paused review of pending state benchmark applications.

Implementation Issues Remain Front and Center

DMHC also addressed implementation of several newer laws. With respect to SB 729, the infertility coverage law, the Department reminded plans that affected products issued, amended, or renewed on or after January 1, 2026 must comply, and that updated EOCs should be submitted with legislative compliance filings due March 19. DMHC noted that it recently amended its prior guidance and may issue FAQs in the coming months. The Department also reiterated that long-acting injectable PrEP drugs may not be denied in favor of oral alternatives on the theory that they are interchangeable. In the licensing space, DMHC said it plans to open eFiling for Pharmacy Benefit Manager (PBM) licensure in July 2026, with a two-step process intended to allow PBMs to obtain conditional licensure by January 1, 2027 while completing the remainder of the application during 2027.

What Plans Should Be Watching For plans, the practical takeaway is that DMHC is advancing several regulatory and legislative initiatives at the same time. Developments involving provider directories, prescription drug reporting, fertility coverage requirements, PBM licensure, combination networks, and prior authorization reporting will likely continue to evolve throughout the year. Plans should remain attentive to DMHC guidance and rulemaking activity as these initiatives move forward.

By: Aaron R. Claxton

On February 27, 2026, the Centers for Medicare and Medicaid Services (“CMS”) issued a moratorium on the enrollment of new durable medical equipment (“DME”) suppliers with Medicare. The moratorium applies to the following seven supplier types:

• 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 prosthetics and orthotics  personnel
• Medical supply company with registered pharmacist
• Medical supply company with respiratory therapist

In issuing the moratorium, CMS noted that their determination for the need to implement the moratorium was based on a high risk that fraud, waste, and abuse exists. CMS relied on historical Medicare enrollment and claims data and analyzed key metrics pertaining to enrollment volume and trends for more than eighty types of DME suppliers. Despite a relatively small number of bad actors, DME suppliers continue to be a prime target for allegations of fraud, waste, and abuse.

The moratorium will remain in effect for six months and may be extended thereafter. The CMS notice identifies the following changes that the moratorium does not apply to:

• Changes in practice location (except if the location is changing from a location outside the           moratorium area to a location inside the moratorium area).
•  Changes in provider or supplier information, such as phone number or address.
•  Changes in ownership (except changes in ownership of home health agencies that would require an initial enrollment).

However, the moratorium would apply to suppliers that go through a change of ownership because a supplier that undergoes a nonexempt change in majority ownership within thirty-six months of its initial enrollment must enroll in Medicare as a brand new supplier, despite already operating prior to the moratorium. Additionally, changes of ownership that are the result of asset sales would also be impacted by the moratorium as the new owners would also have to enroll in Medicare as a new DME supplier. Applications submitted to CMS for new enrollment during the moratorium period will be denied and the applications will have to be resubmitted in the future once the moratorium is no longer in place.

The notice indicates that CMS believes the moratorium will not substantially limit Medicare beneficiaries’ access to care because “there is already an adequate nationwide quantity of such suppliers.” However, the number of overall suppliers does not take into account the fact that there may be limited numbers of specific types of suppliers and also fails to consider that there may already be very limited access to Medicare beneficiaries located in certain rural communities.

For existing DME suppliers, this moratorium serves as a barrier to entry to new suppliers that would compete with them for business. DME suppliers currently enrolled in Medicare should note the increased scrutiny that they face for allegations of fraud, waste, and abuse with the current administration. It is as important as ever for DME suppliers to prioritize regulatory and compliance efforts in order to maintain their Medicare enrollment and continue to serve the Medicare beneficiary population.

Aaron Claxton is a California healthcare attorney and partner with Wilke Fleury LLP focused on regulatory compliance for a range of clients providing healthcare services within the state.