Competitive Bidding

We do not expect CMS to make any major changes to competitive bidding at this time. CMS finalized the Round 2028 structure via regulation in the CY2026 Home Health/DMEPOS Final Rule (published Nov. 28, 2025). Implementation is proceeding on CMS' published timeline — CBIC opened Phase 1 (bid preparation) on June 4, 2026, with the bid window targeted for late fall 2026, contract awards in late summer/early fall 2027, and contracts will be effective no later than January 2028.

CMS announced the expected number of Round 2028 contract awards as:

• Class II Continuous Glucose Monitors and Insulin Pumps: 10 contract winners
• Hydrophilic Urinary Catheters: 10 contract winners
• Off-the-Shelf (OTS) Back Braces: 3 contract winners
• OTS Knee Braces: 4 contract winners
• OTS Upper Extremity Braces: 5 contract winners
• Ostomy Supplies: 6 contract winners
• Urological Supplies: 5 contract winners

Before the new contracts take effect (no later than January 1, 2028, per CMS' target timeline), current suppliers continue billing under existing rules — nothing changes until the new contract period starts.

After January 1, 2028, only contract suppliers may bill Medicare for items that are paid for on a purchase basis.  For items in a capped rental period, a non-contract supplier can formally elect to be a grandfathered supplier. A grandfathered supplier may continue furnishing/billing (at the new CBP payment rate) to beneficiaries it was already renting equipment to at the time the contract period starts, for the remainder of that rental period, but only if the beneficiary chooses to stay with the grandfathered supplier rather than switch to a contract supplier. The beneficiary can leave for a contract supplier at any time. Suppliers who do not elect grandfathered status must provide beneficiaries with notice within specified timeframes and retrieve the rented equipment.

No, under the CBP, only contract suppliers (or a narrow, currently defined set of exceptions — e.g., grandfathered suppliers per Question 3 above, or the physician/treating-practitioner and hospital exceptions that apply to OTS braces) may bill Medicare for competitively bid items furnished to a beneficiary in the competitive bidding area. A non-contract supplier generally cannot furnish and bill at the CBP rate outside those exceptions.

Small suppliers may bid as part of a small supplier network rather than individually, but there's no exemption from bidding. A small supplier still has to submit a bid (solo or via a network) and be awarded a contract to become a Medicare competitive bidding contract supplier for these product categories.

There are several requirements to be part of a small supplier network, such as: no more than 20 suppliers per network, each with gross annual revenue not exceeding $3.5 million, and the network must certify it cannot service the entire nationwide competitive bidding area alone but agrees to furnish all items in the awarded category collectively.

Being a small business also does not, by itself, guarantee a contract — CMS has a policy goal of awarding at least 30% of contracts to small suppliers, but that's a target CMS aims for, not a set-aside guarantee.

Yes. For Round 2028, CMS has established one nationwide RID competitive bidding area that includes all states, the District of Columbia, and all the U.S. territories. A contract supplier for a product category must be able to furnish items to all Medicare beneficiaries, which means needing to meet applicable state/territory licensure and be able to ship/deliver into the territories as well as all 50 states.

The rules require a contract supplier to be able to furnish all items within its awarded product category. Contract suppliers also cannot decline to serve a beneficiary. The supplier can meet this obligation by sourcing the obscure product itself, arranging for another supplier to furnish it, or working with the ordering physician to determine whether an alternative product will suffice