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

CRT Bill H.R. 1703 Advances Through Full Energy & Commerce Committee thumbnail CRT Bill H.R. 1703 Advances Through Full Energy & Commerce Committee Earlier this week, we shared that H.R. 1703 advanced through the House Energy & Commerce Health Subcommittee. We are pleased to report that the bill has continued to gain momentum and has now successfully passed out of the full Energy & Commerce Committee unanimously following today's markup. Important Update: Prior Auth Exemption Process – Deadline Extended to May 26, 2026 thumbnail Important Update: Prior Auth Exemption Process – Deadline Extended to May 26, 2026 CMS has just announced that the deadline to opt out of the prior authorization exemption and continue submitting prior authorization requests has been extended to Tuesday, May 26. This extension only applies to suppliers that received a letter from the DME MACs in early March regarding their prior authorization exemption status. CRT Bill H.R. 1703 Advances Through Energy and Commerce Health Subcommittee thumbnail CRT Bill H.R. 1703 Advances Through Energy and Commerce Health Subcommittee As announced during the NCART and AAHomecare Legislative Conference last week, H.R. 1703, the Choices for Increased Mobility Act, was considered and advanced out of the House Energy & Commerce Health Subcommittee. This is a positive step forward for the CRT community. VGM Government Relations Team Advocates for DME in Washington, D.C. thumbnail VGM Government Relations Team Advocates for DME in Washington, D.C. VGM Government Relations team members joined industry leaders in Washington, D.C., this week for a series of impactful advocacy events, including the 2026 AAHomecare Legislative Conference, NCART Legislative Conference, and the AAHomecare Payer Relations Council meeting. BREAKING NEWS: Big Win For DME Industry in North Carolina thumbnail BREAKING NEWS: Big Win For DME Industry in North Carolina Congratulations to ACMESA on the passage of a Medicaid funding bill, which provides important stability for DMEPOS providers and the patients they serve. Invite Your Federal Legislator to the CRT Product Expo in Washington, D.C. thumbnail Invite Your Federal Legislator to the CRT Product Expo in Washington, D.C. During the upcoming NCART/iNRRTS U.S. Rehab Legislative Conference, NCART and U.S. Rehab will host a Complex Rehab Technology (CRT) Product Expo on May 13 from 11:30 a.m. to 2:00 p.m. in Washington, D.C. This Expo is a valuable opportunity for members of Congress and their staff to see firsthand how CRT products impact independence, mobility, and quality of life for individuals with disabilities. Network Bidding Opens New Path for Small DMEPOS Suppliers thumbnail Network Bidding Opens New Path for Small DMEPOS Suppliers CMS released a new FAQ clarifying that small DMEPOS suppliers may form networks to collectively meet licensure, accreditation, and enrollment requirements for the next round of the Competitive Bidding Program. This guidance creates a new pathway for small suppliers to compete, with additional education and networking support available through VGM initiatives. VGM Group Highlights Value of DMEPOS Industry and Commends Efforts to Protect Patients and Communities thumbnail VGM Group Highlights Value of DMEPOS Industry and Commends Efforts to Protect Patients and Communities VGM Group continues to underscore the effectiveness and efficiency of the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) industry and its critical role across the healthcare continuum. The services and support provided by DMEPOS suppliers not only enhance patient outcomes and strengthen community health, but do so in a cost-effective manner that delivers meaningful savings to the healthcare system.

Give your business an advantage over the competition.

Become a Member