In July 2025, CMS proposed a major change to DMEPOS supplier oversight: moving from a three-year accreditation cycle to annual accreditation for all DME suppliers.
This rule, if finalized, would reshape how DME businesses maintain billing privileges, allocate resources, and manage compliance year-round.
Here’s what the proposed rule includes, what it means operationally, and how your team should prepare.
Background: Why DME Accreditation Exists
CMS began requiring accreditation for DMEPOS suppliers in 2009, following mandates from the 2003 Medicare Modernization Act. Suppliers must meet quality and performance standards verified by a CMS-approved accrediting organization (AO).
Accreditation is currently valid for three years, with an unannounced resurvey required during that cycle.
Accreditation impacts a supplier’s ability to bill Medicare.
If it lapses, even for one day, billing privileges are revoked retroactively.
To date, the system has relied heavily on supplier self-maintenance and AO oversight.
What the Proposed Rule Changes
The proposed rule would shorten the accreditation validity period from three years to one. This means:
- All DME suppliers would undergo full reaccreditation annually
- Accrediting organizations must submit quarterly, detailed data to CMS
- Suppliers must maintain constant survey-readiness, with no blackout periods
- On-site surveys remain unannounced and more strictly timed
- CMS will add real-time oversight of AO surveyors and introduce validation mechanisms
The proposed changes are part of a larger effort to close compliance gaps and reduce fraud, waste, and abuse.
CMS specifically cited cases where suppliers passed accreditation but later operated out of compliance.
Timeline and Enforcement
The proposed annual cycle would take effect no earlier than calendar year 2026.
Suppliers would be expected to renew accreditation annually on their existing anniversary dates, with no grace periods or phase-ins currently outlined.
Failure to maintain valid accreditation would trigger immediate billing privilege revocation, backdated to the day accreditation lapsed.
Who Performs DME Accreditation
There are nine CMS-approved accrediting organizations. All are nationally authorized to evaluate DMEPOS suppliers across product types. These include:
- ACHC
- BOC
- CHAP
- CARF
- HQAA
- The Joint Commission
- The Compliance Team
- DNV Healthcare
- NABP (pharmacy-specific)
These organizations already conduct unannounced surveys and report deficiencies to CMS within two days.
Under the new rule, they would face expanded data and performance reporting obligations.
Operational Impact on DME Suppliers
Annual accreditation means DME providers must remain “survey-ready” all year, not just during the final year of a 3-year cycle.
Some key challenges:
- Increased compliance staffing: Many DMEs will need to designate full-time accreditation leads or expand compliance roles
- Policy updates and training: Staff must stay continually trained on AO quality standards and documentation protocols
- Mock surveys and internal audits: Providers may need to conduct quarterly mock surveys to maintain readiness
- Documentation centralization: Every policy, staff file, delivery log, and training record must be up to date and accessible
- Multiple deadlines: Annual accreditation now needs to align with triennial PECOS revalidation to avoid operational overload
For multi-location suppliers, coordination becomes even more complex as each site must pass its own unannounced survey under tightened timelines.
Cost Considerations
CMS does not regulate AO pricing, but annual surveys will increase costs.
Accreditation typically costs $6,000–$10,000 every three years today.
That could rise to $6,000+ per year, per location under the new model.
Indirect costs also rise, training, compliance tools, mock audits, policy upkeep, and corrective action planning all demand more internal resources.
On the flip side, automation and proactive compliance may reduce exposure to penalties and overpayment recoupments.
Small Provider Impact and Concerns: CMS DME Accreditation
CMS acknowledged concerns that smaller rural providers might drop out of the program under the pressure of annual surveys. This could reduce patient access, especially in underserved areas.
To address this, CMS is considering:
- Hybrid surveys using video walkthroughs for low-risk suppliers
- Tiered AO fee structures based on supplier size or volume
- Technical assistance or pre-survey readiness programs
CMS is accepting public comment on how to reduce administrative burden without compromising oversight.
How to Prepare for Annual Accreditation
Whether or not the rule is finalized as written, DME providers should take steps now to prepare for a higher-frequency survey environment.
Key action items:
- Update Your Quality Management Plan Your QMP should be reviewed and updated quarterly. Maintain a complaint log, track staff training, and keep policies version-controlled and centrally stored.
- Conduct Internal Mock Surveys Use AO checklists to conduct mock surveys at least twice a year. Assign internal leads to walk through delivery, billing, safety, and documentation standards.
- Digitize Documentation Store all proof-of-delivery records, staff files, equipment maintenance logs, and training certificates in a centralized digital location. Make sure they’re accessible for unannounced surveys.
- Track Revalidation and Accreditation Deadlines CMS revalidation notices are posted 7 months in advance. Sync accreditation planning to avoid overlapping deadlines and staffing bottlenecks.
- Budget for Compliance Costs Estimate AO fees under an annual model. Build in buffer funding for corrective action plans, training tools, and possible AO resurvey requests.
The Broader Policy Shift
CMS’s move toward more frequent accreditation reflects a broader pattern. Across multiple provider types, the agency is:
- Demanding real-time compliance visibility
- Increasing data reporting from third-party certifiers
- Standardizing audit timelines and observation protocols
- Cracking down on any signs of “credential inflation”
DME is simply the latest sector under the microscope.
Conclusion
Annual DME accreditation, if finalized, would mark the most significant shift in supplier oversight since the 2009 deadline for initial accreditation.
For providers already stretched by staffing and documentation demands, the move adds both pressure and opportunity.
DMEs that treat this rule as a compliance burden may struggle.
Those that approach it as a chance to professionalize workflows, modernize documentation, and invest in quality systems, will emerge stronger and with a competitive edge.
