Regulatory Update

Medicare Competitive Bidding Returns in 2028 — and Your Denial History Is the Real Entry Fee

CGMs, insulin pumps, ostomy and urological supplies, and off-the-shelf braces are heading into nationwide bidding, with fewer than ten winners per category. Here's what to fix in your documentation workflow before the bid window opens.

DF
DocuFindr Editorial
October 7, 2026• 7 min read

Target dates, not final ones: CMS's Round 2028 schedule has the supplier registration period and bid window opening in late fall 2026, contract awards in late summer or fall 2027, and contracts effective by January 1, 2028. Suppliers who don't win a contract in a category will lose the ability to keep serving those Medicare patients after the six-month transition.

Competitive bidding is back, and it looks different this time

If you ran a DME shop in 2013 or 2016, you remember how competitive bidding worked: regional areas, a long list of categories, and a lot of suppliers who didn't make the cut. The 2028 round is a different animal. Instead of metro-by-metro contests, CMS is running a nationwide Remote Item Delivery program for products that mostly get shipped or picked up rather than set up in the home.

The product list is where most suppliers will feel it. It covers Class II continuous glucose monitors and insulin pumps, urological supplies (hydrophilic catheters get their own category), ostomy supplies, and off-the-shelf back, knee, and upper extremity braces. Oxygen, standard wheelchairs, and CPAP aren't in this round. If your revenue leans on diabetes supplies, catheters, or ostomy, though, a big slice of your Medicare book is in play.

<10contracts per product category, based on the final rule
$50,000bid surety bond required per competitive bidding area
75thpercentile of winning bids now sets the payment amount, not the maximum

Two other changes matter for planning. CGMs and insulin pumps move to a bundled monthly rental payment in both bidding and non-bidding areas, so even suppliers who never bid will see how they get paid change. And bidding consolidates into a single system, which CMS calls Connexion, so the registration and bid mechanics should be less scattered than in past rounds.

"With fewer than ten winners nationally per category, the supplier who can't prove clean operations on paper doesn't get a second look."

Where documentation quietly decides who qualifies

Bid prices get the attention. But before CMS compares a single number it checks whether you're a supplier it can trust: accredited, enrolled, financially sound, and billing cleanly. The financial side is spelled out (credit documentation and the surety bond). The operational side shows up in your own data: how often your claims are denied, how often documentation can't be produced when a reviewer asks, and how many orders you've had to write off.

Look at the categories on the list and you'll spot the problem. Every one of them is a high-volume, recurring-order product with strict paperwork rules. A CGM claim needs a current visit note and the right order details. Catheter and ostomy supplies need quantities and frequencies that match the written order. Off-the-shelf braces get mixed up with custom-fitted ones, which carry a different set of requirements. None of these are hard to document. They're hard to document consistently, at a few hundred files a day, with a rotating cast of referral sources.

Round 2028 categoryWhere files usually breakExposure
CGMs and insulin pumpsVisit note too old, missing treatment-regimen detail, order and visit note disagree on the deviceHigh
Urological and hydrophilic cathetersQuantity or frequency vague on the order, wrong catheter type for the HCPCS code billedHigh
Ostomy suppliesMonthly quantity above usage without a documented reason, no refill confirmation from the patientHigh
Off-the-shelf bracesBilled as off-the-shelf when the fitting was custom, or the reverse; prior authorization checked lateModerate

What a lost contract actually costs

Picture a supplier whose Medicare book is half diabetes supplies and half catheters. They bid, miss the cut in one category, and the 2028 transition clock starts. Over six months, those patients get moved to winning suppliers. There's no appeal that brings them back, and the referral relationships that fed that volume start routing elsewhere too.

Now add the quieter cost. A supplier that spends the next fifteen months chasing denials, rebuilding missing signatures, and answering ADRs is a supplier whose team has no time to prepare a bid. Rework doesn't just burn margin. It burns the same people you'd need to gather financial documents, update accreditation records, and model your pricing against a payment amount set at the 75th percentile of winning bids.

Not sure how your intake files would hold up?We'll review a sample of your recent CGM, catheter, ostomy, or brace orders and show you exactly where documentation breaks before it becomes a denial or a bid-readiness problem.
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The runway between now and 2028

It's easy to treat a January 2028 effective date as someone else's problem. The schedule says otherwise. The bid window is expected this fall, which means the data CMS and your own finance team look at is being generated right now, in the claims you're submitting this month.

Jun 2026
Pre-bid awareness
CMS starts supplier education and previews lead items
Late fall 2026
Registration and bid window
Credentials, financial documents, bond, and bids due
Late summer/fall 2027
Contracts awarded
Winners and payment amounts announced
By Jan 1, 2028
Contracts effective
Six-month beneficiary transition begins

CMS labels these as target dates, and they've moved before. Plan around them, but don't wait for a final announcement to start cleaning up. Nothing on the preparation list below depends on the schedule holding.

A bid-readiness checklist for your intake desk

None of this replaces the bid requirements themselves. It's the paperwork hygiene that makes those requirements easier to meet, and that protects revenue whether or not you win.

Pre-bid documentation readiness checklist
Pull the last 12 months of denials for CGM, insulin pump, urological, ostomy, and brace claims and sort them by reason code
You want to know which document type fails most. If one referral source accounts for a large share, that's your first conversation.
Confirm every active order has a signed, dated written order with specific item, quantity, and frequency
"As needed" and "per patient use" are the phrases that turn into takebacks later.
Check that CGM files have a visit note inside the required window that supports the order
The note date and the order date should tell the same story. Mismatches are easy to spot at intake and expensive to explain on appeal.
Separate off-the-shelf from custom-fitted braces at intake, before the HCPCS code is chosen
Different rules, different prior authorization exposure, and a different risk if the wrong one is billed.
Verify refill and resupply confirmations are on file for recurring supplies
Auto-shipped ostomy and catheter supplies without a documented patient request are an audit magnet.
Keep accreditation, PECOS enrollment, and ordering-provider data current and consistent across your records
Small mismatches in names or NPIs create automated rejects long before anyone looks at the clinical file.
Ask your finance lead what the bond and credit documentation will take, and start gathering it now
The final rule keeps a bid surety bond requirement of $50,000 per competitive bidding area, so know your number early.

Fix the moment of intake, and the rest gets easier

Almost every gap in that table started the same way: a file moved forward before anyone confirmed it was complete. Your coordinators aren't careless. They're checking against memory and a generic checklist while the fax queue grows. The check that would have caught the missing quantity or the stale visit note takes about a minute per file, and a minute per file at that volume is a full-time job.

That's the argument for moving validation to the front of the workflow. Catching a problem when the file arrives costs a phone call to the referring office. Catching it after submission costs an appeal, a delay, and a spot in the data CMS may eventually see. In a market where fewer than ten suppliers per category will hold a contract, a clean file isn't a nice-to-have. It's part of staying eligible for the business.

Here's a reasonable plan for the next two weeks. Pull your denial data. Pick the one category with the worst numbers. Write down, on one page, what a complete file looks like for it. Then check ten recent files against that page and see how many pass. If the answer is fewer than you expected, you've found where to start.

Get bid-ready before the window opens

DocuFindr checks orders, visit notes, and authorizations for gaps at intake, so incomplete files are fixed before submission instead of appealed after denial. Bring us your toughest category and we'll show you what we find.

Sources: CMS, DMEPOS Competitive Bidding Program Updates; CMS, Round 2028 Timeline; VGM, CMS finalizes rule changing the next round of the Competitive Bidding Program; AAHomecare, Competitive Bidding Round 2028.

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