Five areas to put on your calendar
- 1Know your accreditation dateDMEPOS resurvey and reaccreditation is transitioning to at least once every 12 months. If your current three-year accreditation cycle was issued before January 1, 2026, the annual cycle generally begins when that existing cycle expires. Confirm your date, then run the annual self-review checklist.
- 2Protect your Medicare enrollment and PTANRevalidate generally every 3 years for DMEPOS, and monitor Medicare billing activity for every enrollment/PTAN because CMS may deactivate billing privileges after six consecutive calendar months with no Medicare claims.
- 3Keep up with prior authorizationUpper limb prior auth phases in through April 26, 2027.
- 4Schedule coding and reimbursement reviewsCheck HCPCS, fee schedules, and payer rules every quarter.
- 5Give the things without deadlines a deadlineLicenses, bonds, insurance, training, HIPAA, audits, and SOPs, each with an owner.
What ABC and Medicare require
The rules behind the dates. Confirm details with your own accrediting organization and the full regulation.
ABC facility accreditation
- Annual surveys began January 1, 2026. CMS now requires accrediting organizations to survey DMEPOS suppliers every year, replacing the three-year cycle.
- Expiring in 2026? Your renewal runs only until 2027. After that, you apply for accreditation every year.
- Expiring in 2027 or 2028? You move to an annual survey at your next reaccreditation date.
- New location, new owner, or new service needing a survey? You also move to a one-year cycle.
- Standards and fees were unchanged for the 2026 renewal cycle. ABC says more guidance is coming before the 2027 renewal cycle.
Source: ABC, Navigating DMEPOS Accreditation Changes. Accredited by BOC or another organization? Confirm your own transition rules.
Medicare DMEPOS supplier standards
- Report changes within 30 days. Any change to your enrollment information, including location, ownership, and licensure (42 CFR 424.57(c)).
- Accredit every location separately. Each location, owned or subcontracted, must meet the quality standards and be accredited to bill Medicare.
- Tell your accrediting organization when you open a new location.
- Carry at least $300,000 in liability insurance. If you fabricate your own items, it must also cover product liability and completed operations. A lapse can mean revocation back to the lapse date.
- Meet surety bond requirements unless you qualify for an exemption (42 CFR 424.57(d)).
- Give each Medicare patient the supplier standards and keep a complaint resolution protocol.
- Monitor Medicare billing activity for every enrollment/PTAN. CMS may deactivate Medicare billing privileges when no Medicare claims are submitted for six consecutive calendar months (42 CFR 424.540).
Sources: Medicare DMEPOS Supplier Standards (Palmetto GBA); eCFR 42 CFR 424.540.
Before January: check your 2026 changes
2027 month by month
Tap a label to show only that kind of date. Use the lined space under each month for your own deadlines and reminders.
Confirmed published by CMS Recurring happens every year Estimate target or past-year timing Your practice depends on your dates
January2027
- Jan 1RecurringCoding and reimbursementAnnual fee schedule and HCPCS updates take effect
Confirm your system and fee schedules were updated correctly.
- Jan 1ConfirmedPrior authorizationCMS Interoperability and Prior Authorization API requirements begin
Impacted payers must implement specified FHIR-based API requirements, including Prior Authorization APIs. Check with your payers and software vendors about availability and workflow integration.
- Jan 26ConfirmedPrior authorizationUpper limb prior auth (L3761, L3916) phase two begins
Adds AZ, GA, IL, MA, OH, OR, PA, and TX to CA, FL, MI, and NY.
- JanuaryYour practicePractice ComplianceAssign an owner to every deadline on this calendar
Set 30- and 60-day reminders for each one.
- 90 days before your accreditation dateYour practiceAccreditationComplete the annual facility self-review
Use the checklist below so there's time to fix gaps before your survey.
- Early 2027EstimateAccreditationWatch for ABC guidance on the 2027 renewal cycle
ABC has said detailed instructions are coming for the annual cycle.
February2027
- FebruaryYour practicePractice ComplianceAnnual staff compliance training
Keep sign-in records.
No fixed federal dates.
March2027
- MarchYour practicePrior authorizationTrain staff for nationwide upper limb prior auth
Takes effect in every state on April 26.
No fixed federal dates.
April2027
- Apr 1RecurringCoding and reimbursementQuarterly coding and reimbursement review
HCPCS changes from the biannual cycle often take effect now.
- Apr 2ConfirmedPrior authorizationPrior authorization exemption notices
Suppliers in the exemption process may receive continued-exemption or withdrawal notices based on applicable claim-review results; a 90% or greater claim approval rate is required for continued exemption.
- Apr 30ConfirmedPrior authorizationPrior authorization exemption opt-out deadline
Suppliers choosing to opt out of the exemption process must submit the request to their DME MAC by April 30.
- Apr 26ConfirmedPrior authorizationUpper limb prior auth (L3761, L3916) goes nationwide
May2027
- MayYour practiceEnrollment and PTANMid-year Medicare enrollment/PTAN activity check
Review Medicare billing activity for every enrollment/PTAN and address potential six-month inactivity deactivation risk.
- May 18ConfirmedPrior authorizationAdvance PAR submission may begin for suppliers losing exemption
Suppliers losing exemption may begin submitting prior authorization requests in advance of the June 1 cycle.
- MayYour practiceAccreditationMid-year safety check
Fire drill, first aid kits, extinguisher inspections, and chemical labels.
No fixed federal dates.
June2027
- Jun 1ConfirmedPrior authorizationNew annual prior authorization exemption cycle begins
July2027
- Jul 1RecurringCoding and reimbursementQuarterly coding and reimbursement review
- Early JulyEstimateCoding and reimbursementCY 2028 DMEPOS proposed rule released
Look for O&P changes coming in 2028.
August2027
- End of AugustEstimateCoding and reimbursementComment deadline on the proposed rule
September2027
- Late summer to fallEstimateCoding and reimbursementCompetitive bidding contracts announced
Affects off-the-shelf back, knee, and upper extremity braces starting in 2028.
October2027
- Oct 1RecurringCoding and reimbursementQuarterly review and annual ICD-10-CM update
Update diagnosis codes in templates.
- Individual dateYour practicePrior authorizationTrack probationary prior authorization period
For affected suppliers, the one-year probationary period is tied to the supplier's own applicable start date; confirm and track your date.
November2027
- Nov 15RecurringEnrollment and PTANMedicare participation decision window opens
Runs through Dec 31.
- Late NovemberEstimateCoding and reimbursementCY 2028 DMEPOS final rule released
- NovemberYour practicePractice ComplianceHIPAA risk assessment and policy and SOP review
- NovemberYour practiceAccreditationPatient satisfaction survey analysis and performance management plan review
Document improvements for your next survey.
December2027
- DecemberYour practicePractice ComplianceBuild your 2028 compliance calendar
Carry forward every date and owner.
Need help staying ahead of all of this?
You don’t have to manage compliance alone. CBS Medical Billing & Consulting helps O&P practices stay on top of Medicare enrollment, accreditation readiness, coding and reimbursement changes, prior authorization requirements, documentation, audits, payer requirements, and operational compliance.
Let CBS help you identify the gaps before they become problems.
Talk to CBS About Your Practice →Your practice's deadlines
A deadline that everyone is responsible for often becomes a deadline no one is responsible for. Add the date and a name for each item, and your 60- and 30-day reminder dates fill in automatically. Use the blank rows at the end for anything else.
| Item | Due date | Responsible person | Reminders |
|---|---|---|---|
| 1. Accreditation | |||
| Accreditation renewalAt least every 12 months once your current cycle expires | Add a date | ||
| Each location is accredited separately | Add a date | ||
| Annual facility self-reviewAbout 90 days before your accreditation date | Add a date | ||
| 2. Medicare enrollment and PTAN | |||
| Medicare revalidationGenerally every 3 years for DMEPOS | Add a date | ||
| PECOS enrollment accuracy reviewVerify locations, ownership, contacts, and enrollment information | Add a date | ||
| NPPES/NPI accuracy reviewVerify NPI records and practice information | Add a date | ||
| Monitor for six consecutive calendar months with no Medicare claims | Add a date | ||
| Monitor for six consecutive calendar months with no Medicare claims | Add a date | ||
| Monitor for six consecutive calendar months with no Medicare claims | Add a date | ||
| 3. Prior authorization | |||
| Probationary prior auth periodCertain newly enrolled suppliers or applicable ownership changes only | Add a date | ||
| Prior auth exemption statusCycle renews June 1 | Add a date | ||
| 4. Coding and reimbursement | |||
| Quarterly code and fee reviewJanuary, April, July, October | Add a date | ||
| Payer fee schedule reviewCommercial and Medicaid contracts | Add a date | ||
| 5. Things without deadlines | |||
| State licensesReport licensure changes to Medicare within 30 days | Add a date | ||
| Professional credentialsABC or BOC and CE cycle | Add a date | ||
| Surety bond42 CFR 424.57(d), unless exempt | Add a date | ||
| Liability insuranceAt least $300,000; a lapse can mean retroactive revocation | Add a date | ||
| CAQH attestation/review | Add a date | ||
| Commercial payer recredentialing | Add a date | ||
| Medicaid recredentialing | Add a date | ||
| Payer credentialing | Add a date | ||
| Practitioner license/certification and CE deadlines | Add a date | ||
| Employee exclusion screening | Add a date | ||
| Cybersecurity/security risk review | Add a date | ||
| Employee training | Add a date | ||
| HIPAA Security Risk Analysis | Add a date | ||
| Documentation and coding audit | Add a date | ||
| Policies and SOPs reviewInclude complaint resolution protocol and supplier standards notice | Add a date | ||
| Your own items | |||
| Add a date | |||
| Add a date | |||
| Add a date | |||
| Add a date | |||
| Add a date | |||
Annual facility self-review checklist
With accreditation surveys now every year, walk through your facility well before your accreditation date, ideally 90 days ahead, so there's time to fix what you find. Check off what's in place and add notes.
0 of 61 items checked
Business and enrollment records0 of 7
Staff and credentials0 of 7
Policies and programs0 of 6
Facility and postings0 of 8
Patient communication0 of 11
Exam room privacy and safety0 of 5
Lab and workplace safety0 of 13
Billing and compliance0 of 4
A general readiness checklist from CBS Medical Billing & Consulting, built around common survey areas and the Medicare DMEPOS supplier standards. It doesn't replace your accrediting organization's standards. Check theirs for the full requirements.
Compliance shouldn't begin when the audit letter arrives.
Staying compliant is an ongoing process—not a once-a-year project. CBS Medical Billing & Consulting works with O&P practices nationwide to identify compliance gaps, strengthen workflows, prepare for audits and accreditation, and protect reimbursement.
Need help keeping your practice on track? Let CBS be part of your compliance team.
Talk to CBS About Your Practice →Sources
- CMS: Prior authorization for certain DMEPOS items (upper limb phases, exemption cycle)
- AOPA: Three important updates from CMS and Noridian: Face-to-face and WOPD list update, Oct 28, 2026
- HME News: CMS updates several DMEPOS lists (April 13, 2026 prior auth additions)
- CMS: Probationary prior authorization for newly enrolled suppliers
- eCFR: 42 CFR 424.540, deactivation of billing privileges
- Medicare DMEPOS Supplier Standards, 42 CFR 424.57(c) (Palmetto GBA summary)
- ABC: Navigating DMEPOS accreditation changes
- CMS: Interoperability and Prior Authorization Final Rule (CMS-0057-F)
- CMS: DMEPOS Prior Authorization Operational Guide (exemption cycle dates)
- CMS: Competitive bidding program updates
This calendar is provided by CBS Medical Billing & Consulting for educational purposes and general compliance planning only and is not legal advice. Medicare requirements, effective dates, payer policies, and accreditation requirements may change. Practices should verify current requirements with CMS, their DME MAC, accrediting organization, applicable state authorities, and individual payers.