Volume 25.10
CMS has taken steps to increase program integrity of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) providers in the recently finalized “Calendar Year (CY) 2026 Home Health Prospective Payment System (HH PPS) Final Rule recently published.
The Final Rule, includes the following:
Frequency of Surveys and Reaccreditations – DMEPOS suppliers are currently required to be resurveyed and reaccredited for participation in the Medicare program at least every three years. The Final Rule reduces the survey and reaccreditation period to at least once every twelve (12) months
The annual resurvey and reaccreditation cycle will not begin for the respective supplier until the expiration of the supplier’s current reaccreditation three-year cycle if that reaccreditation was used prior to the effective date of the Final Rule, which is January 1, 2026.
Increased Oversight of the CMS Approved Accrediting Organizations (“AO”) – The Final Rule contains provisions that increase CMS’s oversight of DMEPOS AOs. These include:
- Increasing the amount, specificity, and frequency of data the AO must submit,
- Implementing new processes for AOs,
- Expanding CMS’s ability to monitor and review the AO’s operations, and
- Increasing CMS’s ability to respond when the AO is performing in a substandard manner.
Eliminating Temporary Accreditation – Effective January 1, 2026, all DMEPOS suppliers must be surveyed before being accredited. No longer can a DMEPOS supplier secure a temporary accreditation.
Imposing the 36-Month Rule – Under new regulations at CFR § 424.551, a DMEPOS supplier will be subject to the 36-month rule whereby a change in majority ownership within 36 months of the initial enrollment or from the date of the last majority change in ownership would require a new enrollment unless certain exceptions are met.
SNF SPECIAL REVALIDATIONS SUSPENDED INDEFINITELY
Regardless of when a SNF received its notice of revalidation letter from its Medicare Administrative Contractor (“MAC”), there currently is no due date for submission of SNF revalidation applications. The prior January 1, 2026, deadline has been suspended indefinitely.
This suspension also applied to all SNFs that had a pending initial, revalidation, reactivation, or CHOW application as of October 1, 2024, and were requested to submit the new SNF attachment.
PROVIDER ENROLLENT APPLICATION FEE
Effective January 1, 2026, the application fee is $750 for those who are:
- Initially enrolling in the Medicare, Medicaid, or CHIP program,
- Revalidating their Medicare, Medicaid, or CHIP program enrollment, or
- Adding a new Medicare practice location.