At the start of 2026, a new rule took effect from the Centers for Medicare & Medicaid Services (CMS), changing accreditation requirements for durable medical equipment, prosthetics, orthotics and supplies (DMEPOS).
Of those changes, none may be more significant than the switch to annual on-site surveys. But while annual surveys are creating the most buzz, there are other new policy changes and requirements before, during and after the on-site surveys that have significant implications for providers, such as new corrective action plan criteria.
Annual Onsite Surveys
Existing accredited DMEPOS providers (those accredited before Jan. 1, 2026) will be subject to an annual on-site survey when their current three-year contract expires.
New DMEPOS providers who are applying for accreditation on or after Jan. 1, 2026 will be resurveyed and reaccredited annually.
This will require more paperwork and resources for both the accrediting organization (AO) and for providers, but in the long run it will help providers stay compliant, which ultimately improves business operations, patient service and care.
Other Survey Changes
Here are some of the other changes that the 2026 CMS final rule brings.
1. Majority Ownership Change
AOs must perform another accreditation on-site survey for suppliers with a change in majority ownership (more than a 50% direct ownership). If the change in majority ownership is within 36 months of their Medicare enrollment effective date, they must also enroll in the Medicare program as a new DMEPOS supplier. Ownership has always been either an asset sale or stock purchase. With these changes it does not matter—it’s all about majority ownership.
2. Change of Location or Relocation
DMEPOS suppliers are responsible for notifying their AO of a change of location or other relocation. The AO then must conduct another onsite survey at the new practice location.
3. Adding New Locations
DMEPOS suppliers are responsible for notifying their AO when they are opening a new location. The final rule no longer allows an AO to award a 90-day certificate of accreditation so an additional location can operate for three months before the onsite survey. An on-site survey can now only take place once the new location is operational, unless permitted otherwise (i.e., statistical sampling for large chains).
4. Multisite Locations
A large DMEPOS chain is defined as having 25 or more locations. To qualify for sampling, all locations must be seeking or must currently be enrolled in the Medicare program. Sampling is done according to each AO’s policy and methodology. That said, the first 25 are required to have on-site surveys and then a percentage of the remainder, as per each AO’s policy.
5. Adding a New Product Type or Category
A provider must notify its AO if it adds a new product type. A focused on-site survey may need to be performed if the new product is part of a different product category than what the provider was accredited for previously. To save time and money, it’s in the best interest of the provider to plan ahead and add products to coincide with the next annual visit by its AO.
6. Beneficiary Complaints Reported to AO
AOs report complaints to CMS received by the beneficiaries the AO serves. Depending on the severity of the complaint, this could generate another on-site survey to verify and validate that quality standards are still being met and there is resolution.
Clarification & Survey Process Expectations
The final rule also includes additional expectations about the survey process and clarifies that:
Patient records should not include any mock files; they must present only real patients with real problems. If a provider is new, five patient files are required via cash or other payer. For renewal, the provider must have five files that are Medicare patients.
Patient interaction needs to take place during the onsite survey. If the supplier is providing home deliveries, then the AO must go on a home delivery. If the supplier is not providing home deliveries, the observation of patient interaction can take place at the physical location or by phone calls to the beneficiaries.
AOs must deny or revoke the provider if:
- State licensure is not current and the license is needed in order to provide the DMEPOS products and/or services
- The business is not fully operational by being properly staffed, equipped and stocked
- A facility does not meet accessibility requirements (e.g., the provider cannot be in a gated community)
- The AO is directed to by CMS (at CMS’s discretion)
Post-Survey Action
All DMEPOS providers that do not achieve 100% compliance during their accreditation survey will require a corrective action plan (CAP). This would apply to the majority of providers, whether they are new or up for renewal.
CMS has provided strict timelines for AOs to send a CAP to the provider as well as strict timelines for the provider to send back the completed CAP and proof of correction. CMS requires the AO to submit all scoring, CAPs and proof of correction.
The secret to success is staying compliant! Every provider needs to look at this process as continuous and incorporate all policies and processes into their day-to-day practice.
Sandy Canally is founder & CEO of The Compliance Team. She is also a registered nurse with the distinction of being the first nurse oncologist at Hahnemann Hospital and a research liaison to the National Cancer Institute. Canally established The Compliance Team in 1994, where she developed her industry-leading accreditation model that transformed the health care accreditation industry. Visit thecomplianceteam.org.