Medicare Competitive Bidding Round 2028

REIMBURSEMENT PAGE

By Joe McTernan

A major component of the 2026 CMS final rule published Nov. 28, 2025, also known as CMS 1828-F, outlined the pathway for the next round of Medicare Competitive Bidding for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies, which is now being referred to as Competitive Bidding Round 2028. While it is scheduled for implementation beginning Jan. 1, 2028, CMS has indicated that it takes at least 18 months to fully implement each round of competitive bidding and will begin the process in the summer of 2026. 

Let’s take a look at what we know so far and what to expect in Medicare Competitive Bidding Round 2028.

What We Know 

The next round of Medicare competitive bidding will look very different from previous rounds, with the introduction of new product categories and a new delivery model. 

In the final rule, CMS indicated that the following product categories would be included in Competitive Bidding Round 2028:

• Class II Continuous Glucose Monitors and Insulin Pumps
• Urological Supplies
• Ostomy Supplies
• Hydrophilic Urinary Catheters
• Off-the-Shelf (OTS) Back Braces
• OTS Knee Braces
• OTS Upper-Extremity Braces.

Round 2028 introduces OTS upper-extremity orthoses as a new product category that has not been part of previous rounds of Medicare competitive bidding. OTS spinal orthoses and OTS knee orthoses were included in Competitive Bidding Round 2021 but will also be included in Round 2028. 

Historically, it is somewhat unusual to include an individual product category in multiple rounds of competitive bidding as it is unlikely to achieve significant additional savings after it has been through competitive bidding, but Round 2028 will introduce a new delivery model, called Remote Item Delivery (RID), that may result in additional savings to the Medicare program. 

The RID model will rely on the award of a very limited number of competitive bid contracts to suppliers with the capacity to deliver products nationwide using mail-order as its primary method of delivery. In the final rule, CMS indicated that all of the product categories included in Round 2028 will be included in the Remote Item Delivery program and that it intends to award fewer than 10 total RID contracts for each product category. CMS believes that limiting the number of contracts will facilitate increased competition, even for product categories that have already had their fee schedules adjusted based on inclusion on previous rounds of Medicare competitive bidding.

AOPA has obvious concerns about the lack of clinical care that will be available to patients under the RID model that has been proposed for Medicare Competitive Bidding Round 2028 and is actively engaging in discussions with CMS leadership to address these concerns and potential alternatives to inclusion of OTS orthoses in the RID program. AOPA continues to advocate for legislative change, through the Medicare O&P Patient-Centered Care Act, that would extend existing exemptions from Medicare competitive bidding for physicians and therapists to certified orthotists and prosthetists. Extending the exemption would allow O&P providers to continue to provide clinical care to their patients without having to hold a competitive bid contract—although it would be at the rates established through competitive bidding.

What To Expect 

The introduction of the RID model completely changes how O&P providers will participate in Medicare competitive bidding. 

Round 2021, which was the first time that OTS orthoses were included in Medicare competitive bidding, allowed for a somewhat level playing field for submission of bids and participation in the competitive bidding program. 

The RID system that will be used in Competitive Bidding Round 2028 will make it very difficult for most traditional O&P providers to compete for the very limited number of contracts that will be awarded. The logistical challenges of having to distribute products throughout the entire United States will prevent most O&P providers from realistically being able to participate in the program. Major online retailers will have a significant competitive advantage in RID-based bids due to their operational scale and established distribution networks. 

While AOPA continues to advocate for alternatives to the RID model for OTS orthoses, if CMS moves forward, traditional O&P providers will need to make informed decisions that would weigh the cost, time, and energy required to submit bids against the realistic chances of a contract award. Another consideration for traditional O&P providers when submitting a RID bid is the financial impact of bid submission on their operational financial health. Providers must consider whether they can afford to provide OTS orthoses at the rates that will result from a limited number of national contracts.

What Happens Next

Jan. 1, 2028, may seem very far away, but remember that CMS expects the competitive bidding process to take 18 months to implement. Based on this timeline, it is expected that CMS will begin educational efforts about Round 2028 in the very near future. 

The Medicare Competitive Bidding Implementation Contractor (CBIC) website has already been updated with information about Round 2028. Palmetto GBA will continue to serve as the CBIC contractor. Visit this website for announcements regarding Medicare Competitive Bidding Round 2028. If you are not already familiar with CBIC or its website take time to explore it.

AOPA Is Your Source 

AOPA will continue to serve as your advocate to ensure that you are able to continue to provide the best clinical care possible to your patients. We will provide frequent and regular updates on Medicare Competitive Bidding Round 2028 as they are announced.