CMS Issues FAQ On DMEPOS Competitive Bidding Program

Published in Government Relations on January 22, 2026

The Centers for Medicare and Medicaid Services (CMS) has issued a DMEPOS CBP Frequently Asked Questions (FAQ) providing clarification on several points of the next round. The FAQ address several items including physician-owned DME company-related program exemption, including product categories, Remote Item Delivery Competitive Bidding Program (RID CBP) geographic scope, licensure requirements, program timeline, and grandfathering for suppliers providing continuous glucose monitors (CGMs) and insulin pumps. 

If you have any questions after reviewing the FAQ, please don’t hesitate to reach out to Melanie Ewald, melanie.ewald@vgm.com. 

For extended assistance, including support navigating competitive bidding requirements, you can also connect with our van Halem team.

DMEPOS CBP Frequently Asked Questions (FAQ) 

I’m a physician and own a DME company. Am I exempt from the CBP? 

No. The DMEPOS CBP requirements apply irrespective of who owns a DME company and do not exempt any suppliers in a competitive bidding area from a competitive bidding program. 

There are situations where a limited number of competitive bidding items may be furnished by a hospital physician, treating practitioner, physical therapist, or occupational therapist who is not awarded contracts under the CBP. The hospital, physician, treating practitioner, physical therapist, or occupational therapist doesn’t have to be a contract supplier in these cases, and CMS pays for the item based on the applicable single payment amount. 

These situations are as follows: 

• Physicians, treating practitioners, and hospitals may furnish certain types of competitively bid DME without submitting a bid and being awarded a contract under the CBP if all of these apply: 
  • The furnished items are limited to crutches, canes, walkers, folding manual wheelchairs, blood glucose monitors, infusion pumps that are DME, and off-the-shelf (OTS) orthotics; 
  • The physician or treating practitioner furnishes the items to their own patients as part of their professional service or the hospital furnishes the items to its own patients during an admission or on the date of discharge; and 
  • The items are billed under a billing number assigned to the hospital, physician, the treating practitioner (if possible), or a group practice to which the physician or treating practitioner has reassigned the right to get Medicare payment 
• A physical therapist in private practice (as defined in 42 CFR 410.60(c))) or an occupational therapist in private practice (as defined in 410.59(c)) may furnish competitively bid OTS orthotics without submitting a bid and being awarded a contract under the CBP, if the therapist furnishes the items to their own patients as part of the physical or occupational therapy service. 

For more information on these exceptions, visit 42 CFR 414.404(b). 

Do the exceptions to the DMEPOS CBP apply to continuous glucose monitors (CGMs), CGM supplies, ostomy, tracheostomy, or urological supplies? 

No. The exceptions for physicians and other clinicians under §414.404(b) only apply to the items listed under §414.404(b)(1) and (2). 

Will tracheostomy supplies be included in the next round of competition either as a separate product category or under the product category for ostomy supplies? 

No. CMS will not phase in tracheostomy supplies during the next round of competition under the DMEPOS CBP. Until these items are phased into the DMEPOS CBP they can be furnished by any enrolled supplier. 

Do bidding suppliers need to be licensed in all 50 states for the furnishing of items under a Remote Item Delivery (RID) CBP product category? 

Yes. 

Do bidding suppliers need to be licensed in all 50 states before submitting bids for the furnishing of items under a Remote Item Delivery (RID) CBP product category? 

Bidders don’t have to be licensed in all 50 states, Washington D.C., and the U.S. territories before submitting a bid, but bidders must be properly licensed by the close of the bid window and maintain the licenses throughout the bid evaluation process and the contract performance period, if CMS awards them a contract. 

Will there be a RID CBP under the next round of the DMEPOS CBP? 

Yes. In the next round of the DMEPOS CBP, suppliers will bid to provide products for a RID CBP. 

Will the competitive bidding area for the RID CBP be nationwide? 

Yes. 

What will the RID CBP product categories be? 

The product categories in the RID CBP will be: 

• Class II CGMs and insulin pumps 
• Urological supplies 
• Ostomy supplies 
• Hydrophilic urinary catheters 
• OTS back braces 
• OTS knee braces 
• OTS upper extremity braces 

These products will be bid in the same bid window with the same implementation timeline. 

For more information on product categories, visit click here.

Will hydrophilic urinary catheters be classified as a distinct product category, separate from other urological supplies? 

Yes. 

When will the list of the HCPCS codes included under each product category be available? 

We expect to make the list of items under each product category available by early summer 2026. 

Does the DMEPOS CBP include items covered under Medicare Part D? 

No. The DMEPOS CBP only includes the items and services covered under Part B and described under section 1847(a)(2) of the Social Security Act. 

Will suppliers furnishing Class II CGM supplies, ostomy supplies, urological supplies, and hydrophilic catheters that are not awarded contracts under the DMEPOS CBP be able to continue furnishing these items to Medicare beneficiaries that they had a supply arrangement with prior to the start of the contract period? 

No. Medicare beneficiaries getting Class II CGM supplies for Class II CGMs they own, and Medicare beneficiaries who have been getting hydrophilic urinary catheters, ostomy supplies, and urological supplies from suppliers not awarded contracts under the DMEPOS CBP will need to transition to contract suppliers for these items furnished during the contract period. (By law, Class III CGMs are not included in the CBP). 

Will noncontract suppliers furnishing rented class II CGMs and insulin pumps at the time the contract period starts be allowed to continue furnishing the class II CGMs and insulin pumps as grandfathered suppliers? 

Yes. If the noncontract supplier elects to be a grandfathered supplier for these items for beneficiaries renting these items at the time the contract period starts, they must agree to continue furnishing the class II CGMs and insulin pumps that were being rented to any beneficiary who wants to continue receiving the CGMs and/or insulin pump from the noncontract supplier. The beneficiary can elect to transition from the noncontract supplier to a contract supplier for the CGM and/or insulin pump at any time during the contract period even if the non-contract supplier elected to become a grandfathered supplier. Grandfathering does not apply to situations where the supplier has already received payment for 13 months of continuous use for an insulin pump, the title for which will transfer to the beneficiary at the end of the 13th paid rental month. Grandfathered suppliers of class II CGMs and/or insulin pumps will be paid based on the monthly rental amounts established under the DMEPOS CBP with no cap on the rental payments.