2025 DMEPOS & Home Health Proposed Rule

New 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 part responding to them, including providing comments to CMS by Friday, August 29.   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.

The deadline for sharing comments is Friday, August 29 (11:59pm ET)

What's New
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.

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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.   Note: This is a work-in-progress document and subject to change as we continue to gather feedback from the industry.

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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 is actively analyzing the rule and will lead efforts to:

  • Develop and lead comprehensive comment response strategy for the DME community.
  • Engage with Congress and advocacy partners.
  • Educate suppliers to prepare for the next CBP round.
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Resources

Top AAHomecare Resources

Focus on Ostomy, Urological and Tracheostomy

CMS Resources

AAHomecare News & Alerts