Over the past several weeks, there have been several important developments related to DMEPOS accreditation that have understandably caused confusion for pharmacies and DME suppliers. Between new CMS requirements, the temporary loss of accreditation authority by the Board of Certification/Accreditation(BOC), and a subsequent court ruling that reinstated their status, many providers are asking the same question: “What does this mean for my pharmacy, and do I need to act right now?”
This article is intended to provide a clear, steady overview of what has occurred, what remains unchanged, and practical steps to consider depending on your situation.
What Changed: Key CMS and Accreditation Updates
1. CMS Annual Site Inspection Requirement
Earlier this year, Centers for Medicare & Medicaid Services (CMS) announced that all DMEPOS Accreditation Organizations (AOs) will now be required to conduct annual site inspections.This represents a shift toward more frequent oversight and tighter timelines across the accreditation process.
While the DMEPOS Supplier Standards themselves have not changed, the operational expectations around surveys,corrective actions, and documentation have become more rigid, leaving less room for extensions or delays. This may also result in increased fees for suppliers to maintain their accreditation certificates through their Accreditation Organization (AO)
2. BOC Termination — and Temporary Reinstatement via CourtOrder
In early December 2025, CMS announced that it had terminated Board of Certification/Accreditation (BOC) as a CMS-approved Accreditation Organization. At that time, BOC was no longer authorized to perform accreditation or reaccreditation activities. Click here for statement.
However, at a court hearing on January 9, 2026, a Temporary Restraining Order (TRO) was granted against CMS. As a result:
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BOC is once again authorized as a CMS-approved DMEPOS Accreditation Organization
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BOC may provide full accreditation and reaccreditation services in 46 states, restrictions remain in place for CA, FL, NY, and TX
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This status remains effective until further notice
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Please keep in mind this matter did not impact BOC’s certification programs, which were not affected by the termination and remain valid.
What Did Not Change
It is equally important to understand what did not change during this process:
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If your pharmacy or DME facility already holds a valid BOC accreditation certificate, that certificate remains valid until its stated expiration date
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Pharmacies are not required to immediately switch AO’s solely because of these events
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CMS DMEPOS Supplier Standards continue to apply regardless of accreditation status or AO
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For many providers, no immediate action is required,provided no operational changes are planned and accreditation is not nearing expiration.
Practical Guidance Based on Your Situation
If Your Accreditation Expires Soon, timing has become more critical due to survey backlogs and CMS’s stricter posture.
- Expiring in February or March 2026
- Consider requesting an extension directly from CMS: dmeaccreditation@cms.hhs.gov
- Expiring within the next 90 days
- Submit your accreditation application as soon as possible
- Since surveyor visits are unannounced, if they take 4+ weeks to arrive, you may have a window of time where your certificate has expired before the new one can be issued.
- Deficiency reports may take an additional 3–5days
- CMS now requires all Corrective Action Plans(CAPs) to be submitted within 30 days, with no extensions granted by AOs
Winter is upon us and weather delays and increased CMS review requirements have further tightened timelines.
If You Are Accredited Through BOC
- You may remain with BOC, which is often the simplest and most cost-effective option
- Currently BOC has the lowest cost for applications at $2,500 click here for application
- You can choose to tanisition to another AO. Full List of Approved AO's available here.
- If you have any changes (location, ownership, name, or DMEPOS items), contact BOC promptly to ensure updates are processed correctly
- If you are in CA, FL, NY, or TX- BOC is unable to issue Accreditation Certificates for facilities in those states. You will need to work with another AO such as ACHC, The Compliance Team, or HQAA. Full List of Approved AO's available here.
If You Are a Pharmacy with Limited DMEPOS Activity
Some pharmacies may qualify for the Medicare DMEPOS Accreditation Exemption, which allows continued billing without maintaining paid accreditation, provided all CMS criteria are met. This may be a worthwhile option for pharmacies with:
- Minimal DMEPOS revenue (Less than 5% of your pharmacy annual sales)
- Long-standing accreditation history (Accreditation for at least 5 years and in good standing)
- No plans to expand DMEPOS offerings
Even with the exemption, all CMS supplier standards still apply. Click here to see Exemption Fact Sheet
A Note on Competitive Bidding
It's Back! That's right CMS has decided to bring back Competitive Bidding. This time it includes the Nationwide Remote Item Delivery (RID) Program which is the new competitive bidding framework for Medicare DMEPOS items, focusing on items often shipped from remote locations, such as Class II CGMs, insulin pumps, and certain braces. Scheduled to start in 2028, it consolidates local contracts into nationwide or large regional contracts, with suppliers delivering directly to beneficiaries.
Be sure to review the CMS Statement on Competitive Bidding including categories effected here.
If you are planning to participate in the 2028 Competitive Bid, you will need to be actively accredited for the product categories you intend to bid on. Accreditation status should be reviewed well in advance of any bid preparation.
Please note the roll out The estimated number of national awards per category are below:
- Class II Continuous Glucose Monitors (CGMs) and Insulin Pumps: ~10 suppliers
- Urological Supplies: ~8 suppliers
- Ostomy Supplies: ~8 suppliers
- Hydrophilic Urinary Catheters: ~8 suppliers
- Off-The-Shelf (OTS) Knee Braces: ~6 suppliers
- OTS Upper Extremity Braces: ~6 suppliers
- OTS Back Braces: ~4 suppliers
Final Thoughts: Stay Informed, Not Alarmed
There are still moving parts, and additional guidance from CMS may be issued. For now, the most important steps are to:
- Understand your accreditation expiration timeline
- Avoid unnecessary changes unless required
- Act early if renewal or updates are needed
- Maintain compliance with all CMS DMEPOS Supplier Standards
Need Help Interpreting Your Situation?
We will continue monitoring CMS and accreditation developments and will share updates as new information becomes available.
