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Competitive Bidding Round 2028: What DME Suppliers Actually Need to Know
Round 2028 of the DMEPOS Competitive Bidding Program doesn’t work like the rounds before it. Most of it runs as a single Nationwide Remote Item Delivery model: a handful of suppliers per category win the right to furnish an item by mail across the entire country, not just in certain metro areas. If you supply one of seven specific product categories, whether you keep billing Medicare for that item nationally after January 1, 2028 depends on whether you win a contract in this round. Suppliers who don’t win a contract generally lose the ability to bill Medicare fee-for-service for that category once new payment rates take effect, subject to a limited set of exceptions.
What Round 2028 actually is
CMS finalized Round 2028 in its CY2026 Home Health Prospective Payment System Final Rule, and the Competitive Bidding Implementation Contractor (CBIC) administers the day-to-day bidder education, registration, and pricing guidance on its website. Earlier competitive bidding rounds split the country into regional Competitive Bidding Areas, and suppliers bid to serve a specific metro area or region. Round 2028 moves most product categories into a Nationwide Remote Item Delivery (RID) structure instead: CMS awards a small number of contracts per category, and those contract suppliers (often called Medicare contract suppliers) furnish the item nationwide, primarily through mail order and direct shipment rather than local delivery.
That’s a structural shift, not just a new set of items. Under the RID model, there’s no “your area wasn’t included” outcome the way there sometimes was under the old regional system. If your product category is in Round 2028, the competition is national, and so is the exposure.
The seven categories actually affected
Round 2028 covers these categories, and nothing outside this list is part of this round:
Class II CGMs & Insulin Pumps
Lead item A4239 · $273.28 bid limit
Urological Supplies
Lead item A4352 · $8.86 bid limit
Ostomy Supplies
Lead item A4385 · $7.28 bid limit
Hydrophilic Catheters
Lead item A4296 · $8.86 bid limit
OTS Back Braces
Lead item L0651 · $855.26 bid limit
OTS Knee Braces
Lead item L1852 · $691.80 bid limit
OTS Upper-Extremity Braces
Lead item L3916 · $591.58 bid limit
Lead item codes and bid limits are from CBIC’s Phase 1 Bid Preparation release (June 2026). Each category also includes non-lead HCPCS codes priced off the lead item’s single payment amount — confirm the full list on CBIC’s website before billing.
What’s notably not included
CMS updated its own fact sheet specifically to clarify this, which tells you it was a common point of confusion: legacy categories from earlier competitive bidding rounds are not part of Round 2028.
Standard Wheelchairs
CPAP
Hospital Beds
If your business supplies these categories and nothing on the affected list above, Round 2028 doesn’t put your Medicare billing for those items at risk. If you supply both, only the affected lines are exposed.
Does this apply to Medicare Advantage?
No. Round 2028, like the rest of the DMEPOS Competitive Bidding Program, governs Medicare fee-for-service (Original Medicare) only. CMS has stated that its competitive bidding program applies to people with Original Medicare, not people enrolled in Medicare Advantage plans. Medicare Advantage plans are not required to use CBP contract suppliers; they typically negotiate their own supplier networks, coverage terms, and payment rates independently.
In practice, this means a Round 2028 outcome affects a supplier’s ability to bill Medicare FFS for a given category, but does not by itself change any existing Medicare Advantage contracts, network agreements, or commercial payer relationships that supplier holds. Suppliers with a mixed payer base should evaluate Round 2028 exposure against their Medicare FFS volume specifically, not their total book of business.
The timeline, and where CMS’s own pages disagree
CMS’s original fact sheets, going back to late 2025, put bidder registration and the bid window opening at late summer/early fall 2026. CMS’s current competitive bidding site now lists that same step as late fall 2026 instead. That’s a real shift from CMS’s own source, and most secondary coverage is still repeating the older late summer/early fall 2026 language.
What bidding actually requires
Round 2028 tightened the financial and documentation bar for bidders compared to earlier rounds. Before registration opens, it’s worth understanding what a bid actually commits you to.
Bid Surety Bond Requirement
CMS finalized a rule on August 11, 2026 raising the Remote Item Delivery bid surety bond from $50,000 to $100,000, one bid surety bond per bidding entity regardless of how many RID product categories it bids on. This is a recent change; some sources published before August 2026 still cite the older $50,000 figure.
Percentile Pricing
Bid limits for lead items are now calculated using the 75th percentile of winning bids, rather than the maximum winning bid used in earlier rounds.
Contracts Per Category
CMS sets the contract count per category using a formula (125% of suppliers who furnished at least 3% of national utilization for the lead item, rounded, with a minimum of 2). CMS has not yet published final counts; industry groups (AAHomecare, Medtrade) have circulated estimates of roughly 4–10 per category based on 2023–2024 claims data. Treat these as third-party projections, not confirmed CMS figures, until CMS announces final counts using 2025/2026 data.
Small Supplier Networks
Small suppliers who can’t independently meet nationwide licensure requirements may form a network under 42 CFR § 414.418 and bid collectively.
What this means for your business
Example: A DME supplier bills Medicare roughly $2 million a year for Class II CGMs, supplied nationally by mail order. If that supplier wins a Round 2028 contract, that revenue continues under the new contract terms. If they don’t bid, or bid and don’t win, they generally lose the ability to bill Medicare fee-for-service for CGMs nationally once the contract period starts, subject to limited exceptions.
That exposure is specific to Medicare FFS billing for the affected category. Commercial insurance business, Medicare Advantage contracts, and referral arrangements outside Medicare FFS are not directly governed by Round 2028, though a supplier’s overall financial picture still depends on how large a share of revenue that Medicare FFS category represents.
This is why Round 2028 is a business continuity question for affected suppliers, not simply a pricing negotiation you can choose to sit out.
*Reflects Medicare fee-for-service billing for the affected category only. Commercial insurance, Medicare Advantage, and other revenue streams are not directly governed by Round 2028.
Should you bid? A quick decision guide
Why this isn’t optional
Competitive bidding contracts aren’t a pricing negotiation you can decline and still participate in on the old fee schedule. Once contracts take effect for a category, generally only the winning contract suppliers can bill Medicare fee-for-service for that item nationally. A supplier in one of the seven affected categories that doesn’t submit a bid, or bids and doesn’t win, generally cannot bill Medicare fee-for-service for that item nationally after that date, subject to a limited set of exceptions.
The six-month transition period built into the timeline exists because CMS knows this is disruptive for beneficiaries who need to switch suppliers. It is not a grace period that lets a non-contract supplier keep billing as before.
Accreditation, enrollment, and operational readiness
Winning a bid isn’t the only requirement. CMS and CBIC guidance also expects bidders to have their underlying compliance readiness in order before the bid window opens, and gaps here can disqualify an otherwise strong bid.
- Accreditation status. All locations included in a bid must hold current accreditation from a CMS-approved accrediting organization. If any location isn’t accredited yet, start now, since accreditation can take months. See our accreditation preparation service.
- Medicare enrollment and PTAN status. Every location on a bid needs an active Medicare enrollment record (CMS-855S) and a corresponding PTAN. If you’re not yet Medicare-enrolled, don’t assume enrollment can be completed on short notice; DMEPOS applications can take weeks to months. See our Medicare enrollment support.
- State and territory licensure. All locations on a bid must collectively hold current, non-expired state and territory licenses for the categories bid on, verified in PECOS by the close of the bid window.
- Operational capacity for nationwide fulfillment. The RID model means furnishing items by mail or direct shipment nationwide, not regionally. Confirm your logistics and supply chain can support national volume before bidding, not after winning.
- Confirm whether you’re actually affected. Check your product lines against the seven-category list above, not against “competitive bidding” as a general concept.
- Don’t rely on a single source for the registration date. Given the discrepancy between CMS’s own pages, check the CBIC website directly close to the date rather than a fact sheet that may be a year old.
- Review your financial documentation readiness now. Recent rule changes reduced some financial submission requirements, generally now a business credit report with a numerical score or rating, but bidder registration still requires organized business documentation.
- Understand your exposure if you don’t win. If your business depends significantly on one of these seven categories for Medicare FFS revenue, this is a business continuity question, not just a billing question.
| Question | Answer |
|---|---|
| Is this a regional or nationwide bid? | Nationwide, for most Round 2028 categories (RID model) |
| Are oxygen, wheelchairs, CPAP, or hospital beds included? | No, CMS confirmed these are excluded |
| When does the bid window open? | Late fall 2026 per CMS’s current site (previously stated as late summer/early fall 2026) |
| When do new contracts take effect? | No later than January 1, 2028 |
| What happens if I don’t win a contract? | Generally, you can’t bill Medicare fee-for-service nationally for that item after the contract period starts, subject to limited exceptions |
| Does this affect Medicare Advantage? | No, Round 2028 governs Medicare fee-for-service only |
Frequently Asked Questions
Does Round 2028 affect oxygen, wheelchairs, CPAP, or hospital beds?
No. CMS confirmed these legacy categories are not part of Round 2028. Only the seven categories listed above are affected.
What is the Nationwide Remote Item Delivery model?
It’s the structure CMS is using for most Round 2028 categories, where a small number of contract suppliers furnish an item to Medicare beneficiaries nationwide by mail or direct shipment, rather than through regional competitive bidding areas.
When does bidder registration open for Round 2028?
CMS’s current competitive bidding site lists late fall 2026. Earlier CMS fact sheets and most industry coverage stated late summer or early fall 2026. Confirm the current date on the CBIC website before relying on either.
Does Round 2028 apply to Medicare Advantage plans?
No. Round 2028 governs Medicare fee-for-service (Original Medicare) only. Medicare Advantage plans are not required to use CBP contract suppliers and typically negotiate their own supplier networks and payment terms independently.
What happens if I bid and don’t win a contract?
Generally, once contracts take effect for a category, only winning contract suppliers can bill Medicare fee-for-service nationally for that item, subject to a limited set of exceptions.
Is there a grace period after contracts take effect?
There is a six-month transition period built into the timeline, but it exists to help beneficiaries switch suppliers. It is not a grace period that allows a non-contract supplier to keep billing as before.
Sources
- CMS — CY2026 Home Health Prospective Payment System Final Rule and associated DMEPOS Competitive Bidding Program fact sheets
- CMS — FY 2027 IRF PPS Final Rule (CMS-1845-F), bid surety bond increase to $100,000 for Remote Item Delivery bidding, finalized August 11, 2026
- CMS — Competitive Bidding Implementation Contractor (CBIC), Round 2028 timeline, lead item pricing methodology, and April 2026 FAQ guidance (42 CFR § 414.418 small supplier networks)
- CBIC — Phase 1 Bid Preparation release, Round 2028 lead item HCPCS codes and bid limits by product category, June 2026
- AAHomecare — Competitive Bidding Round 2028 program summary
- Foley & Lardner LLP — legal analysis of CMS’s April 2026 Round 2028 guidance
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