Round 2028 Updates for Competitive Bidding & Interoperability Rule FAQ
Published in
Government Relations
on July 22, 2026
Licensing & Accreditation for Round 2028 of the Competitive Bidding Program
On July 15, the Competitive Bidding Implementation Contractor (CBIC) posted a new article regarding Round 2028 of the DMPEOS Competitive Bidding Program.
As published on the CBIC website:
Get Ready for Round 2028 of the DMEPOS Competitive Bidding Program – Get Licensed and Accredited!
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.
Step 1: Get Licensed
All locations on your bid must collectively have current, non-expired state/territory licenses in the Provider Enrollment, Chain, and Ownership System (PECOS) by the close of the bid window, which will open later this year. To stay on track:
- Make sure your CMS-855S Medicare Enrollment Application is up to date with your Medicare Enrollment Contractor (National Provider Enrollment (NPE) Eastern Region DMEPOS contractor (NPEAST) or NPE Western Region DMEPOS contractor (NPWEST)).
- Review the DMEPOS State Licensure Databases on the Medicare Enrollment Contractors’ websites to confirm which licenses are required for your product category(s):
- Verify that all applicable licenses are reflected in PECOS for every location included on your bid.
If a license is current but could expire before the bid window closes, you must renew it and have the updated dates entered in PECOS before the close of the bid window.
Step 2: Get Accredited
Each location on your bid must be accredited by a CMS-approved accrediting organization for all lead and non-lead items in the product category you are bidding by the close of the bid window. Key points to know:
- CMS cannot award contracts to bidders that do not meet accreditation requirements.
- Accreditation exemptions do not apply to the DMEPOS CBP. All pharmacies must be accredited to be eligible, regardless of any general exemptions (e.g., Section 3109 of the Affordable Care Act).
- A list of CMS-approved DMEPOS accreditation organizations is available on the CMS website.
If your locations are not yet accredited, take action immediately, as accreditation can take time to process and must be reflected in PECOS before the bid window closes.
Important: Enrollment Moratorium
CMS implemented a six-month temporary moratorium on accepting initial enrollment applications, effective Feb. 27, 2026. If you are within the scope of the moratorium and need to enroll a new supplier location to bid in Round 2028 of the DMEPOS CBP, the time to prepare is now.
To position yourself for success, you should have your completed enrollment application ready to submit as soon as the moratorium period concludes. Ideally, aim to submit within one week of the moratorium's end date to provide your Medicare Enrollment Contractor sufficient time to process your application before the DMEPOS CBP Round 2028 bid window opens.
Note: The readiness guidance above is provided solely to help suppliers prepare their enrollment applications in a timely manner. As a reminder, this temporary enrollment moratorium remains in effect for six months. If CMS deems it necessary, the moratorium may be extended in six-month increments. CMS has not made a determination whether to extend the moratorium as of July 15, 2026; if extended, CMS will publish a document regarding such extension(s) in the Federal Register.
Stay Informed
The Competitive Bidding Implementation Contractor (CBIC) website is the official information source for bidders and the focal point for bidder education. The CBIC website contains important and helpful resources to ensure bidders have the necessary information to prepare for DMEPOS CBP Round 2028.
To sign up to receive important competitive bidding announcements and reminders, bidders and others are encouraged to Subscribe to receive email updates on the CBIC website.
Here are more helpful resources regarding the Competitive Bidding Program:
VGM Government Relations is here to help and support you each step of the way. If you have any questions, please reach out to Melanie Ewald at melanie.ewald@vgm.com.
CMS Interoperability Rule CMS-0057-F:
Summary and Recommended Preparation Strategies for DMEPOS Providers
As many of you can attest, durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) providers have struggled with inconsistent prior authorization requirements, delayed determinations, duplicate documentation requests, and limited visibility into authorization status for years. CMS’s Interoperability and Prior Authorization Rule aims to ease those struggles.
The rule requires impacted payers to implement and maintain standardized FHIR-based application programming interfaces (APIs) that promote the electronic exchange of healthcare information and prior authorization data. The requirements apply to “impacted payers,” broadly identified as Medicare Advantage organizations, Medicaid and CHIP managed care plans, state Medicaid fee-for-service programs, and Qualified Health Plans offered through federally facilitated exchanges.
Several operational requirements finalized in rule became effective January 2026 with technology and API requirement compliance effective dates to follow January 2027. The following Q&A outlines the rule provisions and impact on DMEPOS providers and provides preparation strategies, so providers are optimally positioned for a smooth transition.
Q: Does the rule regulate DMEPOS providers or just payers?
A: The rule primarily regulates payers requiring them to implement electronic prior authorization capabilities. However, this is not solely a payer initiative as providers will be impacted. Providers should take steps now to position themselves to improve operational efficiency, reduce administrative burden, and advocate effectively for their patients. The organizations that begin preparing now will be better equipped to adapt as health plans increasingly move toward electronic prior authorization workflows and data-sharing requirements.
Q: What operational requirements became effective January 2026?
A: Most notably, the rule requires impacted payers to issue standard prior authorization determinations within seven (7) days and within 72 hours for expedited.
The rule also requires impacted payers to provide specific reasons when prior authorization requests are denied. Generic responses such as "medical necessity not met" will no longer satisfy regulatory expectations. Impacted payers are required to post prior authorization metrics by posting them to their websites.
Q: What technology and API compliance requirements are going into effect January 2027?
A: The rule requires payers to develop functionality to support electronic prior authorization transactions, provider access to patient clinical and claims information, patient access to prior authorization data, and payer-to-payer data exchange when beneficiaries change plans.
Q: What is CMS trying to accomplish with this rule?
A: CMS developed the rule to improve the electronic exchange of healthcare data, as well as to streamline prior authorization processes by improving transparency and access to interoperable patient data, accelerating prior authorization determination timeframes, and reducing administrative friction for patients, providers, and payers.
Q: How will the rule change DMEPOS provider experience?
A: DMEPOS can expect several changes, including:
- Standardized (non-urgent) prior authorization request timelines with determinations within seven (7) calendar days and within 72 hours for expedited (urgent).
- More detailed explanations when prior authorization requests are denied.
- Reduced use of fax as the means for submitting prior authorization, increased use of electronic submission tools, more structured digital documentation and the ability to upload attachments electronically, automated real-time status updates, and standardized clinical data requirements.
Fully embracing the changes can help providers decrease administrative expenses and turnaround times, strengthen referral source relationships, and increase patient satisfaction.
Q: Can payers rely solely on fax as a means for submitting prior authorization?
A: Fax-only submission options for prior authorization would not be compliant under the language of the rule.
Q: What do providers need to do now?
A: There are several steps providers can take now to prepare:
- Engage payers to establish each payer’s specific timeline, provider training and testing opportunities, and overall technology strategy.
- Engage technology (e.g., DME software, RCM, EHR, and interoperability) vendors to establish electronic prior authorization capabilities and functionality, payer connectivity and interoperability capabilities, and future product opportunities where necessary.
- Evaluate current prior authorization workflows to identify potential opportunities for automation and workflow improvement.
- Shore up and standardize clinical documentation processes in advance to facilitate ease of transitioning to increased automation. Work with referral sources to improve documentation consistency related to physician orders, medical necessity records, face-to-face documentation, clinical assessments, and supporting documentation.
- Work with staff on process and workflow changes that will shift from manual tasks (e.g., phone, fax, and portal processes) to workflows managing automation (e.g., ensuring documentation quality, managing electronic workflows, and monitoring and addressing exceptions).
Q: What can a provider do if an impacted payer is not adhering to the decision timeline?
A: VGM Group recently launched Patient Voices: Access to HME Matters, a platform designed to collect stories from patients and providers regarding payer challenges, access barriers, and successful outcomes involving home medical equipment services. Providers are encouraged to utilize Patient Voices to provide much needed examples of issues with the prior authorization timeline or electronic submission processes once implemented. These examples will aid VGM in demonstrating to CMS the real-world impact of policy decisions.
We encourage you to share your experience here: Patient Voices: Access to HME Matters. Access the CMS Interoperability and Prior Authorization Rule fact sheets and additional information here.
For more information and support, reach out to Melanie Ewald at melanie.ewald@vgm.com.