The Centers for Medicare & Medicaid Services (“CMS”) has finalized significant revisions to the DMEPOS accreditation program in the CY 2026 Home Health Prospective Payment System (HH PPS) Final Rule (90 Fed. Reg. 55342). With limited exceptions, CMS adopted the DMEPOS accreditation proposals as issued. The changes are intended to strengthen program integrity and will materially affect DMEPOS suppliers’ compliance obligations.
Key Changes
Annual Accreditation Requirement
- DMEPOS suppliers must now be surveyed and reaccredited at least annually, rather than every three years.
- Existing suppliers will transition to annual reaccreditation after their current three-year accreditation period expires.
- New suppliers accredited on or after January 1, 2026, will be subject to annual reaccreditation from inception.
Changes in Majority Ownership
- A change in majority ownership within 36 months of initial Medicare enrollment or a supplier’s most recent change in majority ownership generally requires the supplier to be surveyed and accredited and enroll as a new DMEPOS supplier.
- Suppliers must always notify their accrediting organization and National Provider Enrollement contractors (NPE”) within 30 days of any ownership change.
- Accreditation does not automatically transfer after merger, acquisition, or sale and an accreditation survey is required when a change in majority ownership occurs.
- NPE contractors may verify accreditation directly with accrediting organizations during enrollment reviews.
New Locations and Relocations
- CMS eliminated the 90-day temporary accreditation allowance for new locations.
- Unless permitted otherwise, new and relocated locations must be surveyed prior to accreditation approval (unless sampling is permitted).
- Suppliers must notify their accrediting organization and NPE contractors within 30 days of opening or relocating.
- Suppliers should expect to undergo another accreditation survey at their new practice location prior to accreditation issuance
Accrediting Organization Oversight
- The final rule strengthens CMS oversight of accrediting organizations through enhanced data reporting, monitoring authority, and conflict-of-interest prevention.
- Suppliers should expect more rigorous and standardized survey activity.
Unannounced Surveys
- All DMEPOS accreditation surveys will continue to be unannounced.
Large Chain Sampling
- Accrediting organizations may use statistical sampling for large chain with 25 or more locations.
- Suppliers with fewer than 25 locations must undergo 100% on-site surveys.
- Large chains are capped at 100 accreditation surveys per calendar year, regardless of total location count.
Takeaways
Collectively, these changes signal a more intensive and continuous accreditation environment for DMEPOS suppliers. Annual surveys, stricter treatment of ownership changes, elimination of temporary accreditation for new locations, and enhanced accrediting organization oversight all increase compliance burdens and transactional risk. Suppliers contemplating ownership changes, expansion, or relocation should carefully assess timing, accreditation status, and enrollment implications well in advance.