CBS Medical Billing & Consulting

Your 2027 O&P compliance calendar

Compliance shouldn't be managed by memory. Use this calendar to track every deadline, put a name next to each one, and set 30- and 60-day reminders before January arrives.

Regulatory information reviewed and current as of October 2, 2026. CMS requirements, payer policies, and effective dates can change. Verify current requirements with CMS, your DME MAC, your accrediting organization, applicable state authorities, and individual payers.

Five areas to put on your calendar

  1. 1
    Know 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.
  2. 2
    Protect 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.
  3. 3
    Keep up with prior authorizationUpper limb prior auth phases in through April 26, 2027.
  4. 4
    Schedule coding and reimbursement reviewsCheck HCPCS, fee schedules, and payer rules every quarter.
  5. 5
    Give 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 reimbursement
    Annual fee schedule and HCPCS updates take effect

    Confirm your system and fee schedules were updated correctly.

  • Jan 1ConfirmedPrior authorization
    CMS 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 authorization
    Upper 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 Compliance
    Assign an owner to every deadline on this calendar

    Set 30- and 60-day reminders for each one.

  • 90 days before your accreditation dateYour practiceAccreditation
    Complete the annual facility self-review

    Use the checklist below so there's time to fix gaps before your survey.

  • Early 2027EstimateAccreditation
    Watch for ABC guidance on the 2027 renewal cycle

    ABC has said detailed instructions are coming for the annual cycle.

February2027

  • FebruaryYour practicePractice Compliance
    Annual staff compliance training

    Keep sign-in records.

No fixed federal dates.

March2027

  • MarchYour practicePrior authorization
    Train staff for nationwide upper limb prior auth

    Takes effect in every state on April 26.

No fixed federal dates.

April2027

  • Apr 1RecurringCoding and reimbursement
    Quarterly coding and reimbursement review

    HCPCS changes from the biannual cycle often take effect now.

  • Apr 2ConfirmedPrior authorization
    Prior 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 authorization
    Prior 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 authorization
    Upper limb prior auth (L3761, L3916) goes nationwide

May2027

  • MayYour practiceEnrollment and PTAN
    Mid-year Medicare enrollment/PTAN activity check

    Review Medicare billing activity for every enrollment/PTAN and address potential six-month inactivity deactivation risk.

  • May 18ConfirmedPrior authorization
    Advance 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 practiceAccreditation
    Mid-year safety check

    Fire drill, first aid kits, extinguisher inspections, and chemical labels.

No fixed federal dates.

June2027

  • Jun 1ConfirmedPrior authorization
    New annual prior authorization exemption cycle begins

July2027

  • Jul 1RecurringCoding and reimbursement
    Quarterly coding and reimbursement review
  • Early JulyEstimateCoding and reimbursement
    CY 2028 DMEPOS proposed rule released

    Look for O&P changes coming in 2028.

August2027

  • End of AugustEstimateCoding and reimbursement
    Comment deadline on the proposed rule

September2027

  • Late summer to fallEstimateCoding and reimbursement
    Competitive bidding contracts announced

    Affects off-the-shelf back, knee, and upper extremity braces starting in 2028.

October2027

  • Oct 1RecurringCoding and reimbursement
    Quarterly review and annual ICD-10-CM update

    Update diagnosis codes in templates.

  • Individual dateYour practicePrior authorization
    Track 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 PTAN
    Medicare participation decision window opens

    Runs through Dec 31.

  • Late NovemberEstimateCoding and reimbursement
    CY 2028 DMEPOS final rule released
  • NovemberYour practicePractice Compliance
    HIPAA risk assessment and policy and SOP review
  • NovemberYour practiceAccreditation
    Patient satisfaction survey analysis and performance management plan review

    Document improvements for your next survey.

December2027

  • DecemberYour practicePractice Compliance
    Build 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.

ItemDue dateResponsible personReminders
1. Accreditation
Accreditation renewalAt least every 12 months once your current cycle expiresAdd a date
Each location is accredited separatelyAdd a date
Annual facility self-reviewAbout 90 days before your accreditation dateAdd a date
2. Medicare enrollment and PTAN
Medicare revalidationGenerally every 3 years for DMEPOSAdd a date
PECOS enrollment accuracy reviewVerify locations, ownership, contacts, and enrollment informationAdd a date
NPPES/NPI accuracy reviewVerify NPI records and practice informationAdd a date
Monitor for six consecutive calendar months with no Medicare claimsAdd a date
Monitor for six consecutive calendar months with no Medicare claimsAdd a date
Monitor for six consecutive calendar months with no Medicare claimsAdd a date
3. Prior authorization
Probationary prior auth periodCertain newly enrolled suppliers or applicable ownership changes onlyAdd a date
Prior auth exemption statusCycle renews June 1Add a date
4. Coding and reimbursement
Quarterly code and fee reviewJanuary, April, July, OctoberAdd a date
Payer fee schedule reviewCommercial and Medicaid contractsAdd a date
5. Things without deadlines
State licensesReport licensure changes to Medicare within 30 daysAdd a date
Professional credentialsABC or BOC and CE cycleAdd a date
Surety bond42 CFR 424.57(d), unless exemptAdd a date
Liability insuranceAt least $300,000; a lapse can mean retroactive revocationAdd a date
CAQH attestation/reviewAdd a date
Commercial payer recredentialingAdd a date
Medicaid recredentialingAdd a date
Payer credentialingAdd a date
Practitioner license/certification and CE deadlinesAdd a date
Employee exclusion screeningAdd a date
Cybersecurity/security risk reviewAdd a date
Employee trainingAdd a date
HIPAA Security Risk AnalysisAdd a date
Documentation and coding auditAdd a date
Policies and SOPs reviewInclude complaint resolution protocol and supplier standards noticeAdd 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.

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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

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.