ABC Submits Comments to CMS DMEPOS Proposed Rule Change

ABC Submits Comments to CMS on CY 2026 Home Health PPS Proposed Rule, Advocates for Patient Access and Operational Flexibility

The American Board for Certification in Orthotics, Prosthetics & Pedorthics, Inc. (ABC) has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) in response to the CY 2026 Home Health Prospective Payment System (HH PPS) Proposed Rule specifically addressing the effects on DMEPOS. ABC supports CMS's goal of strengthening oversight and ensuring quality care but urges the agency to adopt a risk-based, targeted approach to new accreditation and survey requirements.

Key recommendations include:

• Clarity and Reasonable Timelines for Data Collection: ABC supports enhanced reporting but stresses the need for clear guidance and business-day deadlines to ensure feasible compliance.

• Stronger Enforcement Against Supplier Misrepresentation: ABC advocates for granting AOs authority to deny or revoke accreditation for falsified submissions to uphold program integrity.

• Avoiding Redundant Oversight: The organization recommends flexibility for AOs already conducting thorough resurveys, ensuring resources are directed toward addressing noncompliance and protecting patient outcomes.

• Preserving Accreditation Autonomy: ABC warns against penalizing AOs for enforcing compliance, emphasizing that identifying noncompliance should not result in CMS discipline.

• Opposition to Annual Surveys: ABC contends that annual reaccreditation would strain providers—particularly in rural areas—without improving care quality. A risk-based or tiered approach is advised.

• Retention of the 90-Day Accreditation Window: ABC highlights the need for this buffer to support service continuity during transitions.

• Differentiation Between DME and O&P Providers: ABC urges CMS to avoid overgeneralizing fraud concerns, as O&P providers operate under stricter credentialing and ethical standards.

• Flexibility in Survey Scheduling: ABC recommends exemptions to the unannounced survey mandate for in-home and appointment-based care models to maintain access for vulnerable populations.

ABC remains committed to supporting CMS’s mission while ensuring that reforms are practical, evidence-based, and aligned with patient care realities. Your voice is crucial, submit your comments NOW!   

The deadline for submission is August 29, 2025, at 11:59 PM EDT.

Read Full Comments Here