CMS released updated DMEPOS competitive bidding guidance for 2028. Here is what the program is and what to watch.

The Centers for Medicare & Medicaid Services has released updated guidance documents for the 2028 Competitive Bidding Program for durable medical equipment, prosthetics, orthotics, and supplies — the category Medicare calls DMEPOS. It arrived as a quiet policy item. It is not, practically speaking, a minor one.

Competitive bidding shapes who is allowed to supply Medicare beneficiaries in a given geography and at what reimbursement rate. When rates compress or the eligible supplier pool thins out, the effect reaches a patient’s next fitting appointment before they ever hear the words “competitive bidding.”

What the program actually does

CMS operates the Competitive Bidding Program to set reimbursement rates for specific DMEPOS categories by inviting suppliers to bid for contracts. Suppliers that agree to serve Medicare beneficiaries at or below CMS-accepted rates become approved contract suppliers in designated geographic areas. For covered items, beneficiaries in those areas are generally expected to use contract suppliers.

The premise is cost efficiency. The longstanding objection from the O&P community is whether the model can distinguish between a commodity product and a custom-fabricated clinical device — because those are not the same transaction.

You can competitively bid a standard CPAP machine. Pricing pressure there lands mostly on a supply chain. You cannot bid a custom transfemoral socket the same way, because the device and the clinical labor needed to fit it are inseparable, and “fitting” is not a step you can cut to meet a lower rate without it showing up somewhere a patient will feel.

The historical pressure point

Custom-fabricated prosthetic and orthotic devices have generally been excluded from competitive bidding on the grounds that CMS has recognized them as non-commodity clinical products. Off-the-shelf orthotic products — prefabricated ankle-foot orthoses, standard lumbar supports — have appeared in some competitive bidding rounds, and their inclusion has drawn sustained objection from O&P practitioners. The argument is that even a prefab device requires clinical fit judgment, and bidding reduces the reimbursement for that judgment toward zero.

What competitive bidding has historically produced in the categories it covers: lower per-unit reimbursement, some supplier consolidation, and disputes about whether the savings reflect genuine efficiency or reflect suppliers exiting markets where the math no longer works. When suppliers exit, coverage gaps follow. They tend to open first in rural and underserved areas.

What releasing guidance now means

CMS publishing supplier guidance at this stage signals that the 2028 bidding round is entering its formal preparation window. Suppliers need lead time to evaluate their bids: which product categories, which geographic areas, at what rates. That process begins with guidance documents.

The specific changes from prior competitive bidding guidance were not detailed in the announcement reviewed by this desk. O&P EDGE’s report notes that CMS updated the guidance without specifying which categories or rate structures changed from the most recent round. The desk has submitted a request for additional detail and will update this piece when it is available.

What to track from here

The questions that matter as 2028 takes shape:

• Which categories are in scope. Whether any custom O&P categories appear on the 2028 list is the central access question. Their continued exclusion is not guaranteed across administrations; it has been the subject of regulatory back-and-forth for years.
• Whether bidding areas expand. Geographic scope decisions shape where gaps form. Rural supplier deserts have historically tracked with competitive bidding coverage.
• What happens to the supplier base. Rate compression in one round can reduce bidders in the next, which reduces options for beneficiaries regardless of what the policy technically allows.
• Congressional O&P exclusion legislation. Efforts to write the custom fabrication exclusion into law rather than leaving it to regulatory interpretation have been introduced in prior sessions. Whether that push resurfaces during the 2028 run-up is worth watching.

If you are a Medicare beneficiary who uses a prosthetic device or brace, the practical near-term question is whether your current supplier holds contract status in your area. That is searchable at the Medicare Supplier Directory (medicare.gov/care-compare) or through your prosthetist’s office.

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This piece covers a regulatory announcement and general program background. Nothing here constitutes individualized Medicare, insurance, or benefits advice. Coverage questions specific to your situation should go to your prosthetist, insurer, or a qualified benefits counselor.