Proposed Rule suggests Significant Change to Accreditation Process

Published in Government Relations on July 10, 2025

The recently released proposed rule CMS-1828-P contains a significant change that could reshape how suppliers navigate accreditation. The rule proposes a major change that would require suppliers to be surveyed and reaccredited annually instead of the current three (3) year cadence. This proposal raises substantial questions about both operational feasibility and cost implications.

Do Accrediting Organizations Have The Bandwidth? 

Under the new proposal, Accrediting Organizations (AOs) will be tasked with tripling their reaccreditation workload. This poses a serious question: Do AOs have the infrastructure, staffing, and systems in place to maintain the quality and rigor of their evaluations under this accelerated schedule? 

Traditionally, reaccreditation every three years has allowed AOs sufficient time to conduct thorough assessments and offer meaningful feedback to suppliers. Compressing this timeline could risk superficial evaluations, backlog issues, and increased pressure on both accrediting bodies and suppliers to meet compliance standards efficiently. 

Potential Impact on DME Suppliers

Currently, DME suppliers pay an annual fee plus survey fees for accreditation. With the proposed annual requirement, there are several questions as to how AOs will restructure their pricing model to accommodate more frequent surveys and potentially substantial increase in cost to suppliers. 

Final Thoughts 

As the proposed rule undergoes review, stakeholders — from suppliers to AOs — should be actively engaged in assessing the logistical and financial impacts. These decisions will affect not only business operations but also patient access and care quality. Transparency, preparedness, and collaborative planning are critical as this shift unfolds. 

Public Comment Period: Make Your Voice Heard  

It is critical for DME suppliers and stakeholders to participate in the public comment period to ensure that industry perspectives are reflected in the final policy.  

1. Deadline for Comments: Comments must be received no later than 5 p.m. EDT on August 29.  
2. Reference: Please include file code CMS-1828-P in your submission.  
3. Note: CMS cannot accept comments via fax due to staffing and resource limitations.  

How to Submit Comments  

Go to the federal register proposed rule:   

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  

VGM Is With You Every Step Of The Way  

VGM has stood by the DMEPOS community through every round of competitive bidding—and this time is no different. We remain committed to supporting suppliers throughout this process and will continue to provide resources and guidance along the way.  

Stay tuned for more insights as the rulemaking process unfolds.