VGM & ASSOCIATESHealthcare MSO
Full Menu Search

VGM Submits Comments Regarding the Section 232 National Security Investigation On Medical Imports

Published in Government Relations on October 09, 2025

VGM has submitted formal comments to the U.S. Department of Commerce in response to its Section 232 National Security Investigation into the importation of personal protective equipment (PPE), medical consumables, and medical equipment and devices. 

While we recognize the importance of strengthening domestic supply chains and safeguarding national security, VGM emphasized that any resulting trade restrictions must be carefully considered to avoid unintended harm to the durable medical equipment (DME) industry and the patients it serves. 

The submitted comments outlined below include several significant challenges that the DME industry could face if the investigation leads to increased trade restrictions: 

  1. Tariffs and Cost Increases. If new tariffs are imposed on imported medical equipment and components, manufacturers will experience immediate cost hikes. Many essential parts, used in products like wheelchairs, ventilators, and hospital beds, are sourced internationally due to cost and availability. These tariffs could raise production costs, reduce affordability, and limit access for patients and providers. 
  2. Supply Chain Disruption. The DME industry depends on a global supply chain to deliver timely and diverse products. Trade restrictions or tariffs could disrupt this system, causing delays, shortages, and uncertainty, especially critical items like prosthetics, insulin pumps, and glucose monitors that are vital to patient health. 
  3. Limited Domestic Manufacturing Capacity. While boosting domestic production is a worthy goal, current U.S. infrastructure cannot quickly scale to meet demand across all DME categories. Moving away from foreign suppliers without viable domestic alternatives could lead to service gaps. Any shift must consider realistic timelines, investment needs, and workforce readiness. 
  4. Impact on Patient Care and Providers. Higher costs and reduced access to DME products will directly affect patient outcomes. Providers may have to cut services, delay treatments, or pass costs onto patients, undermining healthcare resilience and compromising care quality. 
  5. Risk of Unintended Consequences. Efforts to reduce foreign dependency must be carefully tailored. Broad, one-size-fits-all policies could unintentionally harm U.S. manufacturers who rely on global inputs, stifle innovation, and reduce competitiveness. 

VGM urges the Department of Commerce to take a balanced, collaborative approach that protects national interests without compromising patient care or destabilizing the DME industry. We encourage policymakers to engage with stakeholders across the healthcare continuum to ensure that any future policies support both supply chain resilience and the continued delivery of high-quality, affordable medical equipment to those who need it most.

To submit comments and review the full Section 232 National Security Investigation notice, go to the Federal Rulemaking Portal. 

Get Connected

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

Sign Up for Email

From Our Experts

New CMS Nationwide Probationary Prior Authorization Requirement for Newly Enrolled Suppliers of Certain DMEPOS Items thumbnail New CMS Nationwide Probationary Prior Authorization Requirement for Newly Enrolled Suppliers of Certain DMEPOS Items On Sept. 2, 2026, CMS introduced the Probationary Prior Authorization (PPA) program that will place newly enrolled DMEPOS Suppliers and those undergoing 100% change in ownership on a one-year probationary period. Effective Oct. 15, impacted suppliers will be required to submit a prior authorization request for specific HCPCS codes. OIG Report Signals Increased Fraud Oversight for DMEPOS Suppliers thumbnail OIG Report Signals Increased Fraud Oversight for DMEPOS Suppliers The HHS Office of Inspector General (OIG) recently released a white paper examining ongoing Medicare fraud involving durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). Preparing for Increased Audit Activity: How VGM Group and The van Halem Group Can Help thumbnail Preparing for Increased Audit Activity: How VGM Group and The van Halem Group Can Help The recent HHS Office of Inspector General (OIG) report on DMEPOS fraud signals that CMS is likely to increase oversight activities across the industry. The report calls for enhanced supplier enrollment screening, more aggressive medical reviews, expanded use of artificial intelligence and data analytics, greater physician order verification, and increased scrutiny of supplier ownership and billing practices. CMS Releases Critical Updates On The Medicare Supplier Enrollment Moratorium And Round 2028 Competitive Bidding Program thumbnail CMS Releases Critical Updates On The Medicare Supplier Enrollment Moratorium And Round 2028 Competitive Bidding Program See CMS' notice on the Medicare Supplier Enrollment Moratorium below: Medicare's DMEPOS Supplier Enrollment Moratorium Has Expired | Action Required for Round 2028 Bidders This message is to inform you that the 6-month temporary moratorium on accepting Medicare supplier enrollment applications, which became effective on February 27, 2026, has now expired as of August 27, 2026. CMS Updates CBIC Website Bid Preparation Guidance for Round 2028 Competitive Bidding Program thumbnail CMS Updates CBIC Website Bid Preparation Guidance for Round 2028 Competitive Bidding Program On August 13, 2026, CMS posted several updated and new Fact Sheets and one new FAQ to the Bid Preparation Phase page on the CBIC website. Providers interested in submitting a bid for Round 2028 can find more program details, including the estimated number of contract awards, for each category. Important: HME Supplier Survey on Round 2028 Competitive Bidding Impact thumbnail Important: HME Supplier Survey on Round 2028 Competitive Bidding Impact AAHomecare is conducting a brief survey to help quantify the potential impact that Medicare's Remote Item Delivery (RID) model of Competitive Bidding would have on HME suppliers providing continuous glucose monitors (CGMs), insulin pumps, ostomy supplies, and/or urological supplies. Survey findings will be used to inform discussions with the White House, the Centers for Medicare and Medicaid Services (CMS), and Congress about the potential effects on supplier businesses, jobs, and patient... CMS Makes Finalized Change to DMEPOS Competitive Bidding Program thumbnail CMS Makes Finalized Change to DMEPOS Competitive Bidding Program The Centers for Medicare and Medicaid Services (CMS) has issued the FY 2027 Inpatient Rehabilitation Facilities (IRF) Prospective Payment System (PPS) Final Rule (CMS-1845-F), increasing the DMEPOS Competitive Bidding Program's bid surety bond amount to $100,000 (previously $50,000).... 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.

Give your business an advantage over the competition.

Become a Member