VGM & ASSOCIATESHealthcare MSO
Full Menu Search

Industry Uncertainty And Advocacy Needs – What You Can Do NOW

Published in Government Relations on August 18, 2025

The proposed rule introduces broad structural changes without full clarity on implementation timelines or enforcement. Industry groups like VGM, AAHomecare, and CQRC are urging stakeholders to engage in advocacy to shape final rules. To prepare for the sweeping changes in the 2025 CMS Proposed Rule for DMEPOS, companies should take a multi-pronged strategic approach. Here is a breakdown of key preparation strategies: 

1. Engage in the Rulemaking Process 

Submit formal comments to CMS before the 5 p.m. EST, August 29, 2025, deadline.  Find the link and helpful instructions at the bottom of this article. 

  • Collaborate with industry associations like your State Association, VGM, and AAHomecare to align messaging and amplify impact. 
  • Share data-driven insights on how proposed changes will affect patient access, operational costs, and care quality. 

2. Evaluate Competitive Bidding Readiness 

Assess your product portfolio for items likely to be included in the Remote Item Delivery Competitive Bidding Program (e.g., CGMs, insulin pumps, urological supplies). 

  • Prepare for nationwide or regional bidding by analyzing logistics, fulfillment capabilities, and pricing models. 
  • Consider partnering or consolidating with other suppliers to strengthen bid competitiveness. 

3. Strengthen Operational Efficiency 

Streamline supply chain and inventory management to reduce costs and improve responsiveness. 

  • Invest in technology platforms for order tracking, claims management, and patient communication. 
  • Prepare for dual delivery models (mail-order and in-person) required under RID CBP. 

4. Review Accreditation and Enrollment Compliance 

Ensure your organization is up to date with DMEPOS accreditation standards. Consider products that you may not be accredited for but are being considered as part of the competitive bidding process. These items will have to be approved and listed on your accreditation for consideration. 

  • Monitor CMS updates on provider enrollment changes and prepare documentation accordingly.   
  • Monitor renewal dates for state/local, business, and professional licenses. Bid considerations include an evaluation of licensure requirements. Potential bid winners must have current licenses on file with the provider enrollment contractor. 
  • Train staff on new compliance protocols to avoid delays or denials. 

5. Monitor and Leverage Prior Authorization Exemptions 

Track your claim approval rates to qualify for prior authorization exemptions. 

  • Implement quality assurance programs to reduce denials and improve documentation accuracy. 
  • Implement requirements to continue to maintain all documentation should you qualify for an exemption. 

6. Advocate and Educate 

Educate referral sources and patients about potential access changes and how your company is adapting. 

  • Collaborate with legislators and advocacy groups to ensure patient access and provider sustainability remain priorities. 
  • Stay informed through VGM and AAHomecare alerts, webinars, and policy briefings. 

7. Scenario Planning and Financial Modeling 

Run financial simulations to understand the impact of lower reimbursement rates or lost bids. 

  • Develop contingency plans for product lines at risk of being unprofitable under new rates. 
  • Explore revenue diversification opportunities in private pay, Medicaid, or retail markets. 

How to Submit Comments - Deadline is August 29 

Click here to go to the Federal Register Comment Page.

Choose one of the following methods to submit your feedback:   

  1. Electronically: Submit comments at Regulations.gov. Follow the instructions under the “Submit a Comment” tab.    
  2. By mail: Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1828-P P.O. Box 8013 Baltimore, MD 21244-8013 (Ensure timely delivery before the deadline).   
  3. By express or overnight mail: Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1828-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850. 

Consider the following when drafting comments: 

  • Tailor specific to your business and patients. 
  • Describe any negative impacts the proposed changes would have on your business, your employees, and patients. 
  • Stick to the facts. 
  • No PHI. 

Get Connected

Stay up-to-date on the latest resources and news provided by VGM & Associates.

Sign Up for Email

From Our Experts

CMS Finalizes Rule Changing The Next Round Of The Competitive Bidding Program And Updating Other Provisions Related To Provider Enrollment And Prior Authorization thumbnail CMS Finalizes Rule Changing The Next Round Of The Competitive Bidding Program And Updating Other Provisions Related To Provider Enrollment And Prior Authorization Final Rule Analysis from the VGM Payer Relations and Reimbursement team  On Nov, 28, 2025, CMS finalized Final Rule CMS-1828-F that includes updates to the Competitive Bidding Program (CBP) and other provisions related to provider enrollment and prior authorization. Next round is expected to be implemented no later than Jan. 1, 2028. Celebrating the Life and Impact of Mike Hamilton, ADMEA Executive Director thumbnail Celebrating the Life and Impact of Mike Hamilton, ADMEA Executive Director We are deeply saddened to share the passing of our beloved colleague and friend, Mike Hamilton, Executive Director of the Alabama Durable Medical Equipment Association (ADMEA). For more than 50 years, Mike dedicated his life to the durable medical equipment (DME) industry, setting an extraordinary example of hard work, integrity, and unwavering passion. His leadership and advocacy helped shape the industry and improve access to care for countless patients. The Big Sky Association of Medical Equipment Suppliers Welcomes UTAH! thumbnail The Big Sky Association of Medical Equipment Suppliers Welcomes UTAH! The Big Sky Association of Medical Equipment Suppliers is pleased to announce that Utah has officially been accepted into the association as our newest participating state. Big Sky now proudly welcomes all Utah DME/HME, Respiratory, CRT, and Medical Supply companies into our regional association. Utah will have a designated state representative/director—appointed in the same manner as Montana, Idaho, and Wyoming—to ensure strong representation and a clear voice within the Association. Beyond the Shutdown and The Proposed Rule: Key Legislative Updates for the HME Industry thumbnail Beyond the Shutdown and The Proposed Rule: Key Legislative Updates for the HME Industry While the government shutdown and uncertainty surrounding CMS's Proposed Rule have dominated headlines, several important bills impacting HME providers continue to advance. Here's a quick look at three focused legislative priorities: Advocacy in Action: Texas DME Providers Stand Up For Patient Care thumbnail Advocacy in Action: Texas DME Providers Stand Up For Patient Care Texas DME providers are speaking out against proposed Medicaid reimbursement rate cuts that threaten access to essential medical equipment for vulnerable patients. At a recent public hearing, voices from across the state shared powerful stories about the real-world impact of these cuts—some as high as 85%. The Shutdown Has Ended—Now It's Time To Take Action thumbnail The Shutdown Has Ended—Now It's Time To Take Action The recent government shutdown created uncertainty across the healthcare landscape, and the DMEPOS community was no exception. In the weeks ahead, critical decisions will shape the future of our industry. By getting involved early—through advocacy, education, and collaboration—you can help ensure these policies support patients and providers rather than hinder them. Notably, the Continuing Resolution (CR) includes an extension of Medicare telehealth flexibilities through January 2026... New Issue Brief: Why Medicare's Competitive Bidding Program Needs Urgent Reform thumbnail New Issue Brief: Why Medicare's Competitive Bidding Program Needs Urgent Reform The Medicare competitive bidding program for durable medical equipment (DME) was designed to reduce costs—but it's failing patients and providers. A new issue brief from Pacific Research Institute and economist Wayne Winegarden highlights what changes are urgently needed. Champions of Change: DME Advocates Driving Real Change thumbnail Champions of Change: DME Advocates Driving Real Change Real change starts with real people. In this edition of Champions of Change, we're spotlighting two DME advocates who aren't just talking about problems—they're taking action. David Griffin and Gary Rench are showing us what it means to stand up for patients, providers, and the future of our industry.

Give your business an advantage over the competition.

Become a Member