Important Update from ACHC: CMS Finalizes Annual DMEPOS Survey Requirement

Dec 18, 2025 · Advocacy

NASP encourages members to review this important message from ACHC:

CMS has released the CY 2026 Home Health Prospective Payment System Final Rule, which includes several significant updates to DMEPOS accreditation requirements. These changes affect all DME suppliers enrolled in Medicare and may also impact pharmacies that provide and bill for DMEPOS items.

ACHC remains committed to keeping you informed. We’ve put together a concise walkthrough of the new requirements to support your planning.

Access the CMS Summary

Below is a high-level look at what CMS finalized and what providers should expect as these provisions take effect on January 1, 2026.

1. Annual  cycle for Accreditation

CMS has decreased the length of the accreditation term from once every 36 months to at least once every 12 months.

  • The annual cycle will begin for new suppliers accredited on or after January 1, 2026.
  • For renewing organizations with a reaccreditation survey after January 1, 2026, the term of accreditation will be one year.
  • New and renewing organizations surveyed on or before December 31, 2025, will still be eligible for a three-year term of accreditation that will change to a one-year term with the next survey.

2. Stronger oversight of accrediting organizations

CMS finalized new expectations for AOs, including:

  • Increased reporting requirements.
  • Expanded CMS oversight and monitoring.
  • Clearer processes to ensure AO accountability.
  • Provisions to prevent conflicts of interest.

These measures are intended to strengthen the integrity and consistency of DMEPOS accreditation nationwide.

3. Continuation of unannounced surveys

CMS reiterated that all DMEPOS surveys must remain unannounced, aligning with longstanding practice.

4. Elimination of temporary accreditation

CMS removed the provision allowing a new location for an existing DMEPOS supplier to operate under temporary accreditation without a survey.

Beginning January 1, 2026, all locations must be surveyed prior to accreditation.

5. Change in majority ownership requirements

Suppliers undergoing a change in majority ownership within 36 months of initial enrollment—or within 36 months of a prior ownership change—must enroll as a new DMEPOS supplier and complete a survey and full accreditation process unless a listed exception applies.

6. Continued sampling

CMS will continue to allow sampling methodologies for large supplier chains and intends to engage stakeholders before making any major changes

What happens next?

CMS noted that additional implementation guidance will be issued in the coming weeks. At this time, suppliers do not need to take immediate action beyond reviewing the finalized provisions and preparing for annual reaccreditation surveys before their existing 3-year period expires.

ACHC is actively monitoring CMS communications and will continue to share updates as new information becomes available.

If you have questions about the CMS provisions themselves, CMS encourages suppliers to contact: dmeaccreditation@cms.hhs.gov.

Click here to access the CMS Summary.