As you have heard from AOPA’s previous two communications, CMS released the 2026 DMEPOS/Home Health Final Rule, which includes several significant changes that will directly impact O&P. This final rule takes effect on January 1, 2026.
Since our most recent communication last week, more information has been made available about the accreditation and survey requirements.
As you know, historically, providers were required to undergo accreditation surveys once every 36 months. Under the final rule, suppliers must now be surveyed and reaccredited at least once every 12 months. There are some nuances based on accreditation timing, these are described below.
- Suppliers accredited before the final rule takes effect:
- Your current 3-year accreditation cycle will continue until its scheduled expiration.
- The annual survey requirement begins at the end of that existing cycle.
- Example:
- Accredited June 1, 2023: current accreditation expires June 1, 2026.
- First annual survey must occur by June 1, 2027, then again by June 1, 2028, and annually thereafter.
- Accreditation Organizations may still renew accreditation earlier than the expiration date.
- Suppliers accredited for the first time on or after the rule’s effective date:
- You must be surveyed and reaccredited every 12 months beginning one year from your initial effective accreditation date.
- Example:
- Initially accredited June 1, 2026: annual reaccreditation required by June 1, 2027, and yearly afterwards.
This change represents a substantial shift in accreditation oversight and will require providers to plan for more frequent survey activity, documentation readiness, and operational compliance.
AOPA continues to monitor all components of the rule and subsequent information and will provide ongoing updates, analysis, as well as guidance and tools to help members prepare for implementation.
If you have questions, please contact: Ashlie White at awhite@AOPAnet.org, Joe McTernan at jmcternan@AOPAnet.org, or Devon Bernard at debernard@AOPAnet.org.