Proposed Rule Sets the Stage for the Return of the Competitive Bidding Program
On June 30, CMS issued a Proposed Rule impacting the future of the DMEPOS Competitive Bidding Program (CBP), as well as other key Medicare reimbursement policies.
Find resources and guidance here to help you understand provisions in the Proposed Rule and how you can take action in responding to them, including contacting your members of Congress. Our latest materials and an overview of the Proposed Rule follow below; a complete listing of resources available can be found at the bottom of the page. And action steps you can take are clearly outlined.
Thank you for your support in sharing HME industry perspectives on the Proposed Rule! See AAHomecare's offical comments here.
What's New
- Recruit House Republicans to Join Sign-On Letter on CB Program
- Ask Legislators to contact CMS directly on the proposed rule with special focus on small business – amplifying messages that resonated in recent meetings with the Administration and Capitol Hill
- Letter to Administrator Oz and OMB Director Vought regarding need to remove ostomy, urological, and tracheostomy supplies from the CB proposed rule
- Letter from the Diabetes Caucus to CMS Administrator Oz regarding CGMs in CB
Key Provisions in the Proposed Rule
The Prosposed Rule includes new rate-setting methodologies and bid limits, updates to the DMEPOS accreditation process, expanded product categories, and a formal exemption process from prior authorization for suppliers meeting specified claim approval thresholds.
You can learn more in our alert to members and our Summary of DMEPOS-related provisions in the Proposed Rule. (updated Aug. 1)
Leading DME Industry Response
This Proposed Rule and a restructured CBP will shape the next few years for the DME sector and have impacts on the majority of companies and their employees, and patients. Leaders on our Regulatory Council are developing AAHomecare’s official comments and strategy for mobilizing the DME industry and allied patient/clinician groups to provide a strong and well-informed comment response. We urge suppliers, manufacturers, other DME stakeholders to share their perspectives, concerns, and suggestions with CMS.
Preliminary commenting Guidance for on the DMEPOS/HH Proposed Rule is now available.
Proposed Rule Could Add CGMs, Insulin Pumps & Medical Supplies to Competitive Bidding
CMS’s newly released Proposed Rule marks the first time the agency has formally proposed including continuous glucose monitors (CGMs), insulin pumps, and certain medical supplies in the CBP.
Key Proposals:
- CMS may implement a national or regional Remote Item Delivery (RID) CBP for items typically shipped to patients, such as CGMs and insulin pumps.
- Contracted suppliers would be responsible for furnishing both mail-order and in-person items under RID CBP.
- Phase in the RID CBP and non-CBA rates based on RID CBP competitions.
Medical Supplies in Question:
- CMS also proposes including urological, ostomy, and tracheostomy supplies in future CBP rounds—despite statutory limitations.
- These items are currently covered under the prosthetic benefit and not authorized for inclusion in CBP under the Social Security Act.
- AAHomecare has been working to educate Capitol Hill about this issue; see our related policy document, Competitive Bidding Over-reach on Ostomy, Urological & Tracheostomy Products, for additional detail.
AAHomecare’s Response
AAHomecare is working to ensuring the new bidding procedures support sustainable reimbursement rates and protect access to care. The Association has launched a full campaign, which includes:
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Federal Advocacy & Government Relations: 2 High-level White House Meetings, ranking members of the House and Senate and committees of juridiction, Administration officials from CMS and HHS
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Media & Public Relations: Engagement with a PR Firm and Public Affairs & Digital Strategy Firm to launch and oped and digital campaign targeting the
Washington DC region. The ad campaign has garnered more than 15 million impressions through both traditional television ads, online ads, social media, and digital out of home
advertising.
- Coalition Building & Grassroots Mobilization: AAHomecare supported a multi-channel competitive bidding campaign with the Diabetes Patient Advocacy Coalition (DPAC), as well as worked closely with consumer advocacy organizations like United Ostomy Association of America and ITEM Coalition on grassroots advocacy. AAHomecare also activated its members on an industry letter to CMS Administrator Oz, House Sign-on Letters, and a special focus on the impact to small businesses.
Resources
Top AAHomecare Resources
- Key Issue Summary/Questions on CMS-1828-P and the DMEPOS Competitive Bidding Program
- Commenting Guidance for AAHomecare Members on DMEPOS/HH Proposed Rule -- updated Aug. 20
- Plain Language Messaging for Your Comments
- Summary of DMEPOS Provisions on DMEPOS/HH Proposed Rule (updated Aug. 1)
- Webinar Recording Shaping the Future of HME: Preparing for the Return of Competitive Bidding and Slides available for free to the DME community.
- The CBP End User Action Toolkit gives you everything you need to help your customers speak out.
- CBP & Small Business Fact Sheet
- Competitive Bidding is Not a Tool to Fight Medicare Fraud and Abuse
- CGMs and Insulin Pumps Should Not Be Added to the DME Competitive Bidding Program
- CBP DME Industry Positions Issue Brief
- Letter to CMS Administrator Oz from the Diabetes Caucus regarding CGMs in CB
Focus on Ostomy, Urological and Tracheostomy
- Policy Document: Competitive Bidding Over-reach on Ostomy, Urological & Tracheostomy Products
- Issue Brief: Competitive Bidding Should Not Expand to Include Ostomy & Urological Supplies
- Letter to Congressional Leadership on Ostomy/Urological Products & CB
Media Coverage & Opeds
- Sens. Shaheen and Collins, Reps. DeGette and Bilirakis Warn Administration Against Proposal That Could Harm Diabetic Patients' Access to Glucose Monitors, Insulin Pumps - Press Release - Oct. 27, 2025
- CMS says it’s cutting fraud. Patients like me may pay the price with our lives – Ali Ingersoll, STAT – Oct. 21, 2025
- Unelected Bureaucrats Are Opening America’s Healthcare Door to Beijing To Undermine Trump’s Healthcare Agenda – Laura Loomer - Oct. 1, 2025
- CMS Playing a Dangerous Game on Medical Devices – Elisabeth Hicks, RealClear Health – Sept. 24, 2025
- CMS Shouldn’t Expand Its Broken Competitive Bidding Model – Wayne Winegarden, Forbes – Sept. 12, 2025
- CMS's Competitive Bidding Proposal Ignores Medical Reality – Peter Pitts, Medpage– Sept. 2, 2025
CMS Resources
- Federal Register Page for Medicare and Medicaid Programs: Calendar Year 2026 Home Health Prospective Payment System Rate Update; Requirements for the HH Quality Reporting Program and the HH Value-Based Purchasing Expanded Model; Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Competitive Bidding Program Updates; DMEPOS Accreditation Requirements; Provider Enrollment; and Other Medicare and Medicaid Policies
- CMS Proposed Rule Fact Sheet
- Complete Rule Text (PDF; 519 pages)
- Tips for Developing Effective Comments via Regulations.gov
AAHomecare News & Alerts
- Join HME Industry Letter on CB Program to CMS Administrator Oz - AAH Alert - Oct 25, 2025
- Help Recruit House Republicans to Join Sign-On Letter on CB Program - AAH Alert - Oct 23, 2025
- Full Throttle: AAHomecare Continues to Press Administration and Capitol Hill on CB Program - AAH Insider - Oct 22, 2025
- Continuous Engagement and Compelling Arguments: Making the Case on CB Program Proposals - AAH Insider - Sept 24, 2025
- HME Leaders Pivot to Second Phase of CBP Campaign - AAH Insider - Sept 10, 2025
- AAHomecare Shares Comments to DMEPOS/Home Health Proposed Rule - AAH Alert - Aug 28, 2025
- Don't Miss Out! There's Still Time to Make a Difference on the Return of the CB Program - AAH Insider - Aug 20, 2025
- New Toolkit Available to Help HME Stakeholders Activate End Users to Comment on DMEPOS/Home Health Proposed Rule - AAH Alert - Aug 13, 2025
- Into the Home Stretch on the DMEPOS/HH Proposed Rule - Comments Due Aug. 29 - AAH Insider - Aug 6, 2025
- Focusing on Key Issues in DMEPOS & Home Health Rule - AAH Insider - July 23, 2025
- Meeting the Challenges Head-On - AAH Insider - July 9, 2025
- CMS Releases New DME Competitive Bidding Proposed Rule - Alert - July 7, 2025
- Proposed DME and Home Health Rule Includes Plans to Add CGMs, Insulin Pumps, and Medical Supplies to Bidding Progam - Alert - June 30, 2025