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CMS Changes Accreditation Requirements For All DMEPOS Suppliers Effective January 1, 2026.

Published in VGM Government Relations on December 12, 2025

As we shared last week, CMS finalized the DMEPOS accreditation rule change that requires Accrediting Organizations (AOs) to survey and recredential DMEPOS suppliers annually, instead of every three years. This change is outside of competitive bidding and applies to all DMEPOS suppliers as a condition of Medicare enrollment. 

VGM Group is in frequent communication with the AOs regarding the rule specifics and implementation status. The AOs confirmed they are actively engaged with CMS, having met in aggregate earlier this week, at which CMS clarified when the annual survey and reaccreditation cycle will begin. CMS also recently published a Provision Summary and Q&A document clarifying several aspects of the change, most notably: 

“Frequency of Surveys and Reaccreditation – DMEPOS suppliers have long been required to be resurveyed and reaccredited at least every 36 months (3 years). The final rule reduces the survey and reaccreditation period to at least once every 12 months. 

  • A DMEPOS supplier’s annual resurvey and reaccreditation cycle will not begin until the expiration of the supplier’s current reaccreditation 3-year cycle (if issued prior to the final rule effective date). To illustrate, suppose a supplier was initially accredited or reaccredited for a 3-year period effective June 1, 2023. For purposes of the implementation of our new annual resurvey/reaccreditation requirement – June 1, 2026, is the date: (1) its current accreditation expired; and (2) on which its annual resurvey/reaccreditation cycle begins. Accordingly, the supplier would have to be resurveyed and reaccredited at least once by June 1, 2027, again by June 1, 2028, and so forth. The dates used in this example are not meant to imply that all accreditations must be in effect for exactly 3 years. AOs may issue reaccreditation renewals prior to the expiration date of the current period. 
  • In addition, DMEPOS suppliers seeking initial accreditation for the first time on or after the effective date of this final rule must thereafter be resurveyed and reaccredited annually. If, therefore, a new supplier became initially accredited effective June 1, 2026, it would have to be resurveyed and reaccredited by June 1, 2027, and at least once every 12 months thereafter.” 

"Q6: How long will my current accreditation last? Will it be cut short by the annual survey/reaccreditation requirement? 

A: A DMEPOS supplier’s annual resurvey and reaccreditation cycle will not begin until the expiration of the supplier’s current 3-year accreditation cycle (issued prior to the final rule effective date). More information on this issue will be provided in the coming weeks. 

Q7: Will CMS still allow sampling? 

A: Sampling allows large chains to have a percentage of their locations surveyed. CMS will allow sampling moving forward. Current methodologies will be allowed to continue, and CMS will engage with stakeholders prior to making any large shifts in sampling methodology in the future."

Suppliers should contact their AO for specific questions about their current accreditation.

Find the Final Rule, CMS Fact Sheet, and other resources on VGM’s Competitive Bidding Resource Page and van Halem Group - Competitive Bidding Program. 

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