CMS Proposes Sweeping Changes to Medicare Enrollment and DMEPOS Oversight
09/08/2025
CMS Proposes Major Changes to Medicare Provider Enrollment and DMEPOS Accreditation
The Centers for Medicare & Medicaid Services (CMS) has unveiled significant proposed changes to Medicare provider enrollment and durable medical equipment oversight through its 2026 Home Health Prospective Payment System rule, with implications extending far beyond home health providers.
Medicare Provider Enrollment Overhaul
CMS is proposing substantial changes to how it handles provider enrollment revocations and deactivations. The most significant shift would allow CMS to revoke provider enrollment retroactively, making revocations effective back to the date when non-compliance began, rather than the current 30-day prospective notice period.
Additionally, the proposed rule would permit enrollment revocation based solely on the beneficiary's attestation that the claimed services were never provided or received. This change aims to prevent improper payments to non-compliant providers but could create new challenges for legitimate providers facing disputed claims.
The proposal also includes automatic deactivation of Medicare billing privileges for physicians and non-physician practitioners who haven't ordered, referred, or certified Medicare claims for 12 consecutive months. While designed to reduce fraud through inactive provider numbers, this could create administrative burdens for providers with limited Medicare activity.
DMEPOS Accreditation Reforms
CMS is addressing perceived integrity vulnerabilities in the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) accreditation system. The proposed changes include:
Annual Reaccreditation: DMEPOS suppliers would face annual surveys and reaccreditation instead of the current three-year cycle, which would significantly increase administrative requirements and costs.
Enhanced CMS Oversight: The agency would gain expanded authority to scrutinize both DMEPOS suppliers and accrediting organizations, with requirements for more detailed information during application processes.
Standardization Efforts: New measures would reduce inconsistencies among different accrediting organizations in their oversight approaches.
Prior Authorization Improvements
The proposal introduces a "gold carding" system for high-performing DMEPOS suppliers. Those achieving a 90% prior authorization approval rate would receive exemptions from routine prior authorization requirements. This system includes a 60-day advance notice for both granting and withdrawing exemptions, allowing suppliers time to adjust their processes.
Competitive Bidding Updates
While the proposed rule acknowledges upcoming improvements to the DMEPOS Competitive Bidding Program, specific details about product categories and competition timelines remain undisclosed, with CMS promising future announcements.
Industry Impact and Timeline
These changes represent CMS's most comprehensive update to DMEPOS regulations in years, driven by concerns about fraud prevention and beneficiary protection. However, the proposals could significantly increase administrative burdens, particularly the shift to annual reaccreditation for DMEPOS suppliers.
The public comment period for these proposals closed in early September 2025, with final rules expected to shape Medicare provider operations and compliance requirements for years to come. Healthcare organizations should prepare for potentially substantial changes to their Medicare enrollment and accreditation processes.