In our earlier article, we broke down the key elements of Final Rule CMS–1828–F and what it means for the future of the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program (CBP). But as many in the industry have pointed out, understanding the rule itself is only half the story. After years without a fully active bidding cycle, CMS has laid out a renewed framework, yet many details remain unresolved.
As organizations assess these changes, new questions emerge about how they will be implemented. Ahead of the next competitive bidding cycle, stakeholders are trying to balance what CMS has finalized with what remains unclear.
The return of competitive bidding arrives at a moment when hospitals, clinics, and suppliers are facing increased cost pressures, renewed CMS oversight, and growing patient demand for chronic-use products. Understanding what CMS–1828–F includes and what it leaves unaddressed is essential as organizations prepare for a reimbursement and regulatory environment that may look considerably different by 2028.
Bid evaluation criteria present additional unknowns. While CMS updated pricing methodologies and bid ceilings, the agency has not specified how non-price factors—such as supplier capacity, geographic coverage, financial stability, or historical performance—will influence bid scoring. Stakeholders also want to know whether CMS intends to maintain broad supplier networks or adopt a more limited set of contract suppliers, as this decision will have direct implications for market competition and beneficiary access.
Questions Leaders Should Be Asking Now
When organizations evaluate how to prepare for CMS–1828–F, leadership teams should:
- Assess their dependency on categories likely to enter competitive bidding
- Evaluate whether existing suppliers have the capacity for national or regional distribution under RID-CBP
- Understand the financial impact of potential 10%–20% reimbursement changes
- Develop transition plans for chronic-use patient populations who may be required to switch suppliers
Addressing these issues early allows organizations to identify vulnerabilities, anticipate market changes, and build informed strategies before CMS releases additional guidance.
In its recent Q&A resource, CMS addressed questions about the shift to annual accreditation surveys under CMS–1828–F, offering added clarity on survey expectations, timing, and year-round documentation requirements. While the guidance allows accreditation organizations to streamline certain reaccreditation elements for consistently compliant suppliers, CMS makes clear that the annual cycle will be treated as a full survey—not a scaled-down or abbreviated review.
This clarification is particularly important for smaller suppliers and federally funded clinics that may have limited administrative capacity. The Q&A reiterates the need for continuous readiness, robust internal monitoring, and consistent adherence to quality and performance standards. The release of this resource signals CMS’s intention to implement uniform oversight practices while minimizing disruption during the transition to more frequent survey intervals.
Implications for Federally Funded Clinics
Federally funded health centers, including Federally Qualified Health Centers (FQHCs), rural health clinics, and public hospitals, may be disproportionately affected as CMS–1828–F is implemented. These providers serve high volumes of patients who rely on chronic-use supplies, often within constrained budgets and tightly managed supply chains. Supplier consolidation, narrower contract networks, and increased oversight could disrupt access and influence referral patterns, requiring clinics to reassess supplier relationships to maintain continuity of care for medically underserved populations.
Uncertainty Around Product Categories
A central area of uncertainty involves which product categories CMS plans to include in the upcoming bidding round. Although CMS–1828–F identifies several categories that could be competitively bid—such as continuous glucose monitors, insulin pumps, urological and ostomy supplies, hydrophilic catheters, and multiple off-the-shelf orthotic products—the agency has not confirmed which will ultimately appear on the final category list. For suppliers, this uncertainty may require preparing bids across multiple categories, adjusting inventories, or making early decisions about entering or exiting specific product lines. For hospitals and clinics, the stakes involve continuity of care and procurement strategy, because category selection directly affects which items may require contracting with competitively bid suppliers and how patient access could shift in the next cycle.
Operational Details for RID-CBP Remain Undefined
The operational framework for the Remote Item Delivery Competitive Bidding Program (RID-CBP) introduces a second layer of ambiguity. While the rule enables CMS to conduct bidding at a regional or national scale for items shipped directly to beneficiaries, it does not outline the performance standards or operational expectations suppliers will need to satisfy. Requirements related to delivery timeliness, documentation of shipment and receipt, inventory thresholds, and logistics capabilities have not yet been defined. Without clarity on these benchmarks, suppliers cannot fully assess whether they can or should participate in RID-CBP, nor can hospitals and clinics evaluate which suppliers are best positioned to meet patient needs under this emerging delivery model.
What These Unknowns Could Mean for the Market
Information on timing, exceptions, continuity-of-care expectations, and CMS support for transition logistics is unclear. While CMS has indicated that a transition period will occur once new contracts take effect, little detail is available on how beneficiaries, particularly those using chronic, high-utilization items, will be guided through supplier changes. Providers and suppliers alike require this information to plan patient communication, training, and access strategies.
These uncertainties suggest a period of significant transition and adjustment for the DMEPOS sector. The shift toward national or regional bidding under RID-CBP may advantage suppliers with large-scale logistics infrastructure, potentially accelerating consolidation in the supplier market. New product categories, especially those with high utilization, may see downward pressure on reimbursement once Single Payment Amounts (SPAs) are established, influencing pricing strategies and product availability.
Provider–supplier relationships are also expected to evolve as organizations evaluate whether current partners intend to bid, have the operational capacity to meet updated requirements, or are likely to secure contracts. Smaller suppliers may face challenges with annual accreditation, expanded financial reporting, and more complex logistics, while larger suppliers may pursue expansions or mergers to strengthen their competitive position.
As the industry awaits additional details, CMS–1828–F clearly signals a significant shift in the competitive bidding framework. We encourage healthcare providers and suppliers to closely monitor CMS updates, engage early with emerging implementation requirements, and proactively address open questions ahead of the next competitive bidding round, expected no later than 2028. Early internal planning, supplier evaluations, and compliance readiness will be critical to navigating these forthcoming changes with greater clarity and confidence.