VGM & ASSOCIATESHealthcare MSO
Full Menu Search

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.  

Get Connected

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

Sign Up for Email

From Our Experts

VGM Government Relations Launches State Payer Resource Hub for DMEPOS Providers thumbnail VGM Government Relations Launches State Payer Resource Hub for DMEPOS Providers This resource brings together key information frequently used by DMEPOS providers. Kentucky Governor Announces Reprieve from Previously Announced Kentucky Medicaid 4% Rate Cut thumbnail Kentucky Governor Announces Reprieve from Previously Announced Kentucky Medicaid 4% Rate Cut The administration expects the surplus funding to sustain current reimbursement levels through June 2027. NAAOP and OPGA Co-Host Second Annual In-Person Legislative Fly-In thumbnail NAAOP and OPGA Co-Host Second Annual In-Person Legislative Fly-In Last week, over 30 stakeholders, advocates, and leaders from around the O&P profession convened at the offices of Powers Pyles Sutter & Verville PC in Washington, D.C., as part of the National Association for the Advancement of Orthotics and Prosthetics' (NAAOP) second annual in-person legislative fly-in. Round 2028 Updates for Competitive Bidding & Interoperability Rule FAQ thumbnail Round 2028 Updates for Competitive Bidding & Interoperability Rule FAQ On Nov. 28, 2025, the Centers for Medicare & Medicaid Services (CMS) announced plans for Round 2028 of the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program (CBP). If you plan to bid, the time to prepare is now... What DMEPOS Providers Need to Know About H.R. 3514: Improving Seniors' Timely Access to Care Act thumbnail What DMEPOS Providers Need to Know About H.R. 3514: Improving Seniors' Timely Access to Care Act Medicare Advantage prior authorization continues to be one of the most significant operational and patient care challenges facing DMEPOS suppliers. A new bipartisan bill, H.R. 3514: Improving Seniors' Timely Access to Care Act, seeks to increase transparency, accountability, and oversight of Medicare Advantage prior authorization practices. This bill passed out of Ways & Means markup by a unanimous vote (42-0) on July 15... H.R. 1703 Advances, Bringing Greater Choice for Wheelchair Users thumbnail H.R. 1703 Advances, Bringing Greater Choice for Wheelchair Users The DMEPOS community, particularly wheelchair providers and users, should be celebrating an important victory as the House approved the Choices for Increased Mobility Act (H.R. 1703). North Carolina Medicaid Rate Floor Extended Through 2029 thumbnail North Carolina Medicaid Rate Floor Extended Through 2029 Earlier this year, it was announced that the North Carolina General Assembly has approved the state budget, securing an additional full two-year extension of the Medicaid fee schedule floor. This protection will now remain in effect until June 30, 2029, guaranteeing that reimbursement rates will continue to be set at 100% of the lesser of the supplier's usual and customary rate or the maximum allowable Medicaid fee-for-service rate. State Medicaid Work Requirements: The Impact on Medicaid beneficiaries and their DME Suppliers thumbnail State Medicaid Work Requirements: The Impact on Medicaid beneficiaries and their DME Suppliers Pursuant to the work and community engagement requirements included in H.R.1, the Centers for Medicare & Medicaid Services (CMS) has issued an interim final rule mandating a framework for Medicaid departments to follow when evaluating Medicaid beneficiary eligibility. Beginning no later than January 1, 2027, states must require certain adult Medicaid enrollees to demonstrate at least 80 hours per month of qualifying activity, which may include employment, education, or community...

Give your business an advantage over the competition.

Become a Member