Basic Requirement
As a bidder in the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program (CBP), you must have all applicable state/territory licenses for every item in the product category you are bidding on (Section 1847(b)(2)(A)(v) of the Social Security Act) by the close of the bid window. Specifically, you must be properly licensed for each State, the District of Columbia (D.C.), and any U.S. Territory where you would furnish competitively bid DMEPOS items and services to Medicare beneficiaries.
All locations collectively on your bid must meet all applicable licensing requirements for every item in the product category. If a State/Territory requires a specific license, the bidder must ensure at least one of its locations meets the applicable requirements.
Note: You do not need to be licensed in all 50 states, D.C., and U.S. territories before submitting your bid – but all required licenses must be current and non-expired in the Provider Enrollment, Chain, and Ownership System (PECOS) by the close of the bid window. These licenses must also be kept current and non-expired in PECOS throughout the bid evaluation process, and, if awarded a DMEPOS CBP Contract, through the entire DMEPOS CBP contract performance period.
What the Centers for Medicare & Medicaid Services (CMS) Will Check
During the bid evaluation process, CMS will verify your licenses through PECOS. Specifically, CMS will confirm that each of your supplier locations (identified by a Provider Transaction Access Number (PTAN)) listed on your bid meets all applicable requirements for all items in the product category you are bidding on.
Network Bidding Option for Small Suppliers
Under 42 CFR § 414.418, small suppliers that cannot independently furnish all items in a product category across the entire geographic area of a competitive bidding area (CBA) have the option of joining a network.
- To be awarded a DMEPOS CBP Round 2028 Contract, all network member locations included on the bid must collectively meet all applicable enrollment requirements, including accreditation and applicable licensing for each for each State, D.C., and U.S. Territory included in the nationwide remote item delivery (RID) CBA.
- This allows small suppliers to combine their capabilities and collectively satisfy requirements they may not be able to meet on their own.
Keep Your Enrollment Up to Date
Make sure your CMS-855S enrollment application is current with your respective Medicare enrollment contractor – National Provider Enrollment Eastern Region DMEPOS contractor (NPEAST) or National Provider Enrollment Western Region DMEPOS contractor (NPWEST). To be awarded a DMEPOS CBP Contract, you will need to be enrolled in PECOS for all States/Territories and products you currently provide — or plan to provide — if awarded a contract.
The DMEPOS Licensure Database Directory on the Medicare Enrollment Contractor’s’ websites list general licensing requirements and contact information for each State's/Territory’s licensing board. It is important to note that this is a guide only — licensing rules can change, and it is your responsibility to ensure your licenses are current and reflected in PECOS by the close of the bid window.
Important Notice Regarding Moratorium
CMS implemented a 6-month temporary moratorium on accepting initial enrollment applications, effective February 27, 2026. If you are within the scope of the moratorium and need to enroll a new supplier location to bid in Round 2028 of the DMEPOS CBP, the time to prepare is now.
To position yourself for success, you should have your completed enrollment application ready to submit as soon as the moratorium period concludes. Ideally, aim to submit within one week of the moratorium's end date to provide the Medicare Enrollment Contractors sufficient time to process your application before the DMEPOS CBP Round 2028 bidding window opens.
Note: The readiness guidance above is provided solely to help suppliers prepare their enrollment applications in a timely manner. As a reminder, this temporary enrollment moratorium remains in effect for six months. If CMS deems it necessary, the moratorium may be extended in six-month increments. CMS has not made a determination whether to extend the moratorium as of June 4, 2026; if extended, CMS will publish a document regarding such extension(s) in the Federal Register.
After a Contract is Awarded
Once DMEPOS CBP Contracts are awarded, here is what you need to know as a DMEPOS CBP supplier (contract supplier):
- You must maintain compliance with all required licenses for the entire contract performance period.
- Only those locations (PTANs) identified on the bid will be included on the contract, and those are the only locations eligible for payment if the bidder is awarded a contract.
- If one of your locations is not included on the contract, it likely failed to meet one or more bidding requirements.
Adding a Location After Contract Award
After a DMEPOS CBP Contract is awarded, if a contract supplier has any location(s) they would like to add to the contract, the supplier may submit a Change of Location (COL) request in Connexion, the DMEPOS CBP’s secure portal, for the location(s), regardless of whether the location(s) was originally included on the bid for the CBA and product category combination (competition). As a reminder, each of the bidder’s locations is not required to meet all State/Territory and local licensing requirements for the RID CBA. Rather, the bidder must ensure that it holds all applicable licenses such that, collectively, its locations are legally permitted to furnish the product category items to all beneficiaries within the RID CBA. A location would be eligible to be added to a contract if the location is licensed in one applicable State, District of Columbia, or any U.S. Territory in the RID CBA.
- If the COL request is submitted prior to the implementation of DMEPOS CBP Round 2028 and all applicable enrollment requirements (e.g., licensure and accreditation) for the location are met, the qualified location will be added to the DMEPOS CBP Contract, effective on the start date of the contract performance period.
- If the COL request is received after the implementation of Round 2028 and all applicable enrollment requirements for the location are met, the qualified location will be added to the DMEPOS CBP Contract, effective on the date the COL request is received in Connexion.