CMS dropped a bomb on the DME industry.

On December 2, 2025, the Centers for Medicare & Medicaid Services published the final rule for the next round of the DMEPOS Competitive Bidding Program. The industry response? Over 950,000 public comments—most of them concerned, many outright opposed.

CMS didn't budge.

The next round starts January 1, 2028, whether we're ready or not. And if the reaction tells us anything, most DME providers aren't prepared for what's coming.

I've spent the last two weeks talking to DME owners and operators across the country. The anxiety is real. But here's what I've learned: the providers who survive—and thrive—won't be the ones who resist change. They'll be the ones who adapt faster than their competitors.

This guide breaks down everything you need to know about the 2028 competitive bidding round and, more importantly, what you should be doing right now to prepare.

What's Actually Changing (And Why It Matters)

The Big Picture

The final rule makes several significant changes to how competitive bidding will work:

1. Remote Item Delivery (RID) Goes National

Instead of hundreds of local competitive bidding areas, CMS is creating a nationwide Remote Item Delivery program—or several large regional programs—for specific product categories.

Product categories included:

• Continuous Glucose Monitors (CGMs) - first time in competitive bidding
• Insulin pumps
• Urological supplies
• Ostomy supplies
• Tracheostomy supplies
• Off-the-shelf (OTS) braces (knee, back, upper extremity)

What this means for you: Geographic advantages disappear. You're now competing with suppliers across the entire country—or large multi-state regions—not just your local market.

2. Pricing Methodology Changed

Previously, single payment amounts (SPAs) were calculated using the maximum winning bid. Now they're calculated using the 75th percentile of winning bids.

Translation: Pricing will be more competitive, and margins will likely be tighter. The days of riding on high local pricing are over.

3. Annual Accreditation Required

CMS is moving from a 3-year accreditation cycle to annual re-surveys and renewals.

What this means: More frequent compliance checks, more administrative burden, and zero room for letting standards slip.

The Timeline: Mark Your Calendar

Here's the exact sequence of events between now and 2028:

January 2026 (Now)

• Final rule published
• Pre-bidding supplier awareness program begins

Late Spring/Early Summer 2026

• CMS announces specific registration and bidding dates
• Lead items for each product category announced
• Number of contracts per category revealed
• Bidder education program launches

Late Summer/Early Fall 2026

• Bidder registration opens (get your user IDs and passwords)
• Bid window opens

Late Summer/Early Fall 2027

• Contracts awarded
• Single payment amounts announced
• Beneficiary education begins

January 1, 2028

• Contracts and SPAs go into effect
• Six-month transition period begins for beneficiaries to switch suppliers

You have 3 years. Sounds like a lot of time. It's not.

The Five Things You Must Do in Q1 2025

I'm not going to sugarcoat this: most DME providers are going to wait until late 2026 to start preparing. That's a mistake. The providers who start now will have a massive advantage.

Here's your Q1 2026 action plan:

1. Get Your Accreditation House in Order (Like, Yesterday)

Why this matters: You cannot bid without current accreditation for your product category. Period.

What to do now:

• Verify your accreditation status for every product category you plan to bid on
• Check expiration dates—don't let anything lapse
• If you're not accredited for a category you want to bid on, start that process NOW
• Update your NSC (National Supplier Clearinghouse) records
• Ensure your accrediting organization is CMS-approved

Pro tip: With annual accreditation coming, treat compliance as a continuous process, not a once-every-three-years scramble.

2. Audit Your Licensing (Every Single Location)

Why this matters: CMS requires current, non-expired licenses for all lead and non-lead items in each product category. Missing one license? Your entire bid is invalid.

What to do now:

• Inventory all licenses at every location
• Check expiration dates for the next 3 years
• Identify any gaps (new product categories, new locations)
• Ensure PECOS reflects all current licenses
• Create a renewal tracking system so nothing expires during the bid window

Reality check: Licensing requirements change. Don't assume what worked in previous rounds will work in 2028.

3. Run Financial Stress Tests on 75th Percentile Pricing

Why this matters: SPAs will be lower than previous rounds due to the 75th percentile methodology. Can your operation survive on tighter margins?

What to do now:

• Model your costs at various pricing scenarios (assume 10-20% lower than current reimbursement)
• Identify where you can reduce operational costs without sacrificing quality
• Calculate your break-even point for each product category
• Determine which categories are worth bidding on and which aren't

Hard truth: Some product categories may no longer be profitable at competitive bidding rates. Know this before you waste time bidding.

4. Automate Everything You Can

Why this matters: Competing on price alone is a race to the bottom. The winners will compete on efficiency.

What to do now:

• Audit your current workflows: order intake, eligibility verification, prior authorization, billing
• Calculate hours spent on manual tasks
• Identify automation opportunities
• Evaluate automation platforms (full disclosure: this is what GenHealth does, but the principle applies regardless of vendor)

The math: If you're spending 40+ hours/week on prior authorizations and order processing, that's a full-time salary you could be saving—or redirecting to growth.

Competitive advantage: When pricing is tight, operational efficiency is the only way to maintain margins. The suppliers with the most streamlined operations will underbid competitors and still turn a profit.

5. Build Your National Fulfillment Capability

Why this matters: If you win a national RID contract, you need to be able to serve beneficiaries anywhere in your region—or the entire country.

What to do now:

• Assess your current geographic coverage
• Identify gaps in your fulfillment network
• Explore partnerships with regional suppliers
• Evaluate logistics and shipping capabilities
• Test your systems for remote order fulfillment

Reality: Most DME providers are set up for local service. National contracts require national capabilities. Start building that infrastructure now.

What Happens If You Don't Prepare

Let me be blunt: if you wait to start preparing, you're probably going to lose.

Here's what "losing" looks like:

• Incomplete bids rejected due to licensing or accreditation issues
• Uncompetitive pricing because you don't know your true costs
• Contract wins you can't fulfill because your operations aren't ready

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