What are the requirements for DME billing in 2026?
DME billing has never been a simple process, but 2026 brings a new set of changes that make staying current more important than ever. New enrollment rules, updated documentation requirements, and shifting Medicare standards are all in play this year.
Here's what you need to know about DME billing requirements this year, whether you're new to DME or a seasoned supplier.
1. Core Enrollment Steps
DME billing with Medicare starts with a formal enrollment process. Skipping any one of these steps will prevent you from receiving reimbursement.
Obtain accreditation from a CMS-approved accrediting organization
The first step is accreditation from a CMS-approved organization. ACHC, CHAP, and The Joint Commission are among the most common. Accreditation verifies that your operation meets quality and compliance standards. Plan for this process to take three to six months, and budget accordingly for initial fees and annual renewals.
Acquire a National Provider Identifier (NPI) for each location
Medicare enrollment is location-specific and each one carries its own NPI. This unique 10-digit identifier is used across all Medicare and insurance transactions. You can apply for an organizational NPI (Type 2) through the NPPES online portal. It's free and typically issued quickly after you submit your application.
Submit an enrollment application through PECOS
Once accredited and credentialed, you'll enroll as a Medicare supplier using the CMS-855S application through the Provider Enrollment, Chain, and Ownership System (PECOS). Expect the review process to take 60 to 90 days. The application requires detailed business information, ownership disclosures, and background checks on anyone with 5% or more ownership in the business.
Hold a valid surety bond and comply with operational standards
Medicare requires DMEPOS suppliers to maintain a surety bond of at least $50,000 per location. Beyond the bond, ongoing compliance with supplier standards is part of the enrollment picture – more on those can be found below.
2. Core DME Billing Requirements
Enrollment gets you in the door. But once you're billing, every claim is subject to a set of documentation and clinical standards. These are the core billing requirements that determine whether your claims get paid.
Maintain a Valid Standard Written Order (SWO)
Every piece of DME requires a valid physician order before you can bill for it. A Standard Written Order must include the patient's name, date of the order, a detailed description of the item, the treating practitioner's name and NPI, and a signature.
For many items, CMS now also requires a Written Order Prior to Delivery (WOPD), meaning the order must be in hand before equipment ships. CMS expanded the WOPD list in 2026, so more items now fall under this requirement.
Conduct and Document a Face-to-Face (F2F) Encounter
For certain equipment categories, Medicare requires a face-to-face examination between the ordering physician and the patient before the order is written. As of April 13, 2026, CMS has expanded the list of items requiring both a face-to-face encounter and a WOPD, making documentation of these encounters more critical than ever.
Encounter documentation covers the date, the conducting provider, and the clinical rationale for the equipment ordered.
Execute Standardized Proof of Delivery (POD) Protocols
Proof of delivery is a billing requirement. POD documentation includes the patient's name, delivery date, a description of the item, and the patient or authorized representative's signature. Missing or incomplete POD is one of the most common reasons DME claims get denied or flagged during audits.
Establish Robust Medical Necessity and Clinical Justification
Medical necessity documentation is where many claims fall short. The clinical record establishes why the patient requires the specific equipment. This includes the diagnosis, relevant test results, functional limitations, and evidence that less costly alternatives were considered first.
Medicare auditors specifically review whether the clinical record supports the item billed. Gaps here lead to denials and, in audit situations, recoupment demands.
3. Supplier Standards and Ongoing Compliance
Getting enrolled is one thing, but staying compliant is an ongoing commitment. CMS now enforces strict annual reaccreditation, requiring DMEPOS suppliers to maintain constant compliance with all updated standards throughout 2026.
Meet Medicare DMEPOS Supplier Standards
Medicare's DMEPOS supplier standards include 30 detailed requirements covering how you operate your business day to day.
Business and Operational Requirements
- Maintain a physical business location with visible hours and posted licenses
- Operate in compliance with federal, state, and local laws
- Keep accurate and up-to-date enrollment records
- Report changes (ownership, address, etc.) within required timeframes
- Implement fraud, waste, and abuse prevention policies
Product and Service Requirements
- Supply medically necessary equipment based on valid physician orders
- Provide safe, FDA-compliant products
- Educate beneficiaries on proper use, maintenance, and warranty coverage
- Maintain complete documentation and patient records
Quality and Safety Standards
- Maintain a quality assurance and performance improvement program
- Monitor and report equipment issues, adverse events, and failures
- Maintain complaint resolution procedures
- Implement emergency preparedness and contingency plans
Compliance and Oversight
- Maintain active accreditation and pass periodic inspections
- Allow CMS audits and site visits
- Ensure the business and its owners remain in good standing (not excluded from federal programs)
- Avoid prohibited practices such as improper billing or location sharing violations
What are the New Requirements in 2026?
Several notable changes have taken effect or are on the horizon this year. Here's what's new:
Expanded Required List and F2F Encounters
As noted above, CMS has expanded the list of items requiring a face-to-face encounter and a Written Order Prior to Delivery as of April 13, 2026. Items that previously didn't require a WOPD may now fall under these stricter requirements.
Nationwide Enrollment Moratorium
Effective February 27, 2026, CMS imposed a six-month nationwide moratorium on new Medicare enrollments for "medical supply companies." This moratorium is a direct response to concerns about fraud in certain supplier categories. Suppliers currently in the enrollment process will want to confirm with CMS whether their business type is affected.
Competitive Bidding Program 2026 Timeline
The next round of the competitive bidding program, now referred to as the "RID CBP", doesn't officially start until January 1, 2028. But 2026 is the critical bidding year, and preparation is underway for suppliers looking to participate in the next round. If you operate in a competitive bidding area, staying on top of bid submission requirements this year will determine your ability to serve Medicare patients in those markets going forward.
Fee Schedule and Payment Updates
For 2026, most DMEPOS items saw a 2.0% net increase in the Medicare fee schedule. This reflects a 2.7% CPI-U increase offset by a 0.7% productivity adjustment. While the increase is modest, understanding how fee schedule rates apply to your specific product mix matters for revenue planning and evaluating the profitability of your payer mix.
Staying Ahead of DME Billing Requirements
The volume and complexity of DME billing requirements, and the pace at which they change, creates real operational risk for suppliers who rely on manual processes. Missing a WOPD requirement, failing to document a face-to-face encounter, or submitting a claim with incomplete medical necessity documentation can trigger audits, recoupment, and even enrollment consequences.
By managing these requirements effectively, suppliers will have strong intake workflows, clear documentation protocols, and systems that flag issues before claims go out the door.
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