LUGPA Policy Alert: CMS Finalizes Major DMEPOS Reforms and Competitive Bidding in the CY 2026 Home Health Rule

December 2025 

At-a-Glance Essentials

• What’s Changing:
  CMS finalized sweeping DMEPOS reforms for 2026 and a full national restart of Competitive Bidding for 2028—including urological supplies and hydrophilic catheters as bid products for the first time.
• Why It Matters to Urology:
  Annual supplier accreditation beginning in 2026 may strain smaller, rural DME vendors, risking supplier drop-off, shipment delays, and reduced access to clinically appropriate catheters. Competitive bidding in 2028 is projected to result in payment cuts and consolidation among only a handful of national suppliers.
• Action Points:
  Identify at-risk DME supplier partners; prepare for potential product disruptions; begin internal planning for patient transition workflows tied to 2028 contract suppliers; monitor CMS pre-bid guidance.

• Key Dates:

• December 2025: Supplier awareness begins.
• Late spring/early summer 2026: Bidder education, registration dates announced.
• Late summer/early fall 2026: Bidding opens.
• Late summer/early fall 2027: Contracts awarded, SPAs announced.
• No later than January 1, 2028: Implementation with transitions.

Introduction

CMS’s CY 2026 Home Health Final Rule includes the most significant changes to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) program in more than a decade. Two provisions will directly affect independent urology practices and their catheter-dependent patients:

1. Stricter DMEPOS supplier enrollment and accreditation starting January 1, 2026.
2. Full restart and expansion of DMEPOS Competitive Bidding (CBP) under a new national Remote Item Delivery (RID) model beginning January 1, 2028.

For the first time, urological supplies, including standard and hydrophilic intermittent catheters, drainage bags, leg bags, and irrigation supplies, will be subject to competitive bidding. Hydrophilic catheters will be treated as their own product category.

Key Provisions Effective January 1, 2026: Heightened Supplier Scrutiny

Annual unannounced surveys replace the current 3-year accreditation cycle. CMS also gains expanded authority over accrediting organizations, and inactive NPIs may be deactivated without notice.

Why it matters for urology:
Smaller, rural DME suppliers, often local partners who understand urology patients’ needs, may be unable to absorb the cost and operational burden of annual reaccreditation. This increases the likelihood of supplier drop-offs, delayed shipments, and reduced availability of clinically appropriate catheters.

Competitive Bidding Effective January 1, 2028 (RID-CBP)
Beginning in 2028, Medicare’s national competitive bidding program will expand to include several additional product categories, notably:

• Urological supplies (standard and hydrophilic catheters, drainage systems, and irrigation products)
• Ostomy supplies

Potential Effects

• Reimbursement for urological supplies is expected to decline substantially relative to today’s fee schedule.
• A limited number of national contract suppliers are likely to participate, reducing supplier diversity.
• Hydrophilic catheters will be bid as a separate category, adding complexity to product selection and inventory management.

Implications for Urology Practices

Patient Access & Clinical Risk
Catheter selection—material, coating, diameter, and tip design—is individualized to reduce UTIs, strictures, bleeding, and urethral trauma. Patients with neurogenic bladder, post-prostatectomy urinary dysfunction, or chronic incontinence are susceptible to disruptions in supply. Competitive bidding could restrict access to specific catheter types that clinicians rely on for safe, evidence-based care.

Supplier Network Disruption
Previous competitive bidding rounds have led to supplier consolidation and market exits. With national bidding and heightened accreditation requirements, some longstanding regional suppliers may no longer choose to participate. This may result in longer delivery times, fewer product options, and service gaps, particularly affecting rural and medically complex patients.

Administrative & Financial Burden

• Annual accreditation requirements will raise operational costs, accelerating supplier consolidation.
• Lower reimbursement rates may increase patient coinsurance obligations.
• Practices will face significant administrative work transitioning patients to new contract suppliers in 2028, including refitting products, reordering supplies, and managing patient questions and delays.