WASHINGTON, D.C. – CMS recently published the CY 2027 Home Health and DMEPOS Proposed Rule. The proposed rule contains several proposals that would impact DMEPOS suppliers, including:

• DMEPOS Replacement Clarification: For items on the Required Face-to-Face (F2F) Encounter and Written Orders Prior to Delivery List, replacement items will not require a new F2F encounter if the items fall within the same HCPCS code. However, a new F2F encounter is required if the replacement item has a different HCPCS code.
• Expansion of CMS Provider Enrollment Policies: Expands all of CMS’ revocations to be retroactive to the date of non-compliance, sets more reapplication bars regardless of denial reason, and new retroactive authority for “high-risk” enrollments. In addition, a managing employee’s history such as misdemeanor convictions, debt, and program terminations, can trigger a denial or revocation for the provider.
• Clarification Effective Date of Moratoriums: Clarifies that temporary moratoriums will be effective on the date the moratorium notice was filed with the Office of Federal Register, making the effective date immediate, before the notice is published on the Federal Register.
• DMEPOS Definition Expansion to Include External Infusion Pumps and Drugs: Effective April 1, 2027, DMEPOS definition will expand to include certain external infusion pumps and associated home infusion drugs. To qualify for coverage, the drug must be infused at least 12 times per year (at least once a month) and require a health care professional (such as a physician or registered nurse) to be physically on-site at the home to administer or supervise the administration
• Require Country of Origin Reporting for CBP Lead Item: Contract suppliers will need to report country of origin for the lead item on Form C.

CMS is requesting stakeholder comments on the proposals and is accepting comments until August 31, 2026. AAHomecare has convened a workgroup to develop the Association’s comments.