DMEPOS Record Reviews: Is Your Pharmacy Ready?

By Kevn McNamara, PharmD, CSP, HDDP & Caroline Girardeau, PharmD, MBA, PMP, BCPS, Program Director

Kevn McNamara is an ACHC Pharmacy Surveyor with over 25 years of experience in infusion and specialty pharmacy. She is devoted to helping pharmacies understand ACHC Standards to achieve and maintain accreditation.   

Caroline Girardeau brings more than 30 years of pharmacy experience to her position as Program Director for ACHC Pharmacy and PCAB (Compounding Pharmacy) Accreditation. She combines clinical expertise with a passion for education, quality, and performance improvement to help pharmacies strengthen their practices and deliver safe, patient-centered care.

Posted: July 8, 2026

The CMS CY 2026 Final Rule introduced new requirements for pharmacies billing for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS), increasing oversight and adding new operational considerations.

ACHC published FAQs to explain the changes for infusion (IRX, IRX-NO797), specialty (SRX), and long-term care pharmacies (LTC) that seek accreditation to bill for products categorized as DMEPOS.

The list below includes the most common DMEPOS products billed for pharmacy patients:

  • External infusion pumps (DM12)
  • External infusion pump supplies (DM24)
  • Enteral nutrients and related equipment and supplies (PE03, 04)
  • Parenteral nutrients and related equipment and supplies (PE05, 06)
  • Nebulizer and supplies (R07)
  • Glucose Meters and Supplies (DM05,06)

Accreditation process changes

During the opening conference, your surveyor will ask you for a list of clients/patients for whom you have billed DMEPOS codes, including the products listed above. If you have a DMEPOS PTAN, the list must include clients/patients for whom you have submitted claims for products listed on your addendum. The surveyor will randomly select records for review from the list you provide.

If you are unsure about the product code category, use the HCPCS to Product and Service Code Crosswalk to identify the right DMEPOS product and service code.

Let your surveyor know as soon as the list is available. He or she will quickly review the list to ensure the clients/patients identified meet Medicare Part B requirements.

Initial accreditation

For initial accreditation, your pharmacy must have served a minimum of five patients using at least one of the DMEPOS products or services checked on your CMS-855S and also selected as supplier codes on your ACHC Accreditation application.

If you do not have a DMEPOS PTAN, these patients do not need to be Medicare patients. Client/patient records can be from any payor source, including Medicaid, third-party payors, or cash transactions. Even if your clients/patients are not Medicare beneficiaries, your records still must comply with DMEPOS Quality and Supplier Standards.

Reaccreditation

For organizations seeking renewal of accreditation, the report provided to the surveyor should identify clients/patients for whom Medicare Part B DMEPOS products were billed and for which you are currently accredited. Here are tips to help you find all relevant records:

1. Check for any Medicare DMEPOS clients/patients who have been discharged or were a single sale (e.g., one-time diabetic supply client/patient).

2. Check for Medicare DMEPOS claims submitted either for payment or for denial to allow billing another payor.

3. Has your pharmacy recently changed billing systems or vendors? If yes, check if Medicare was billed in the old system.

CMS exceptions

If, after exhausting all options, you do not have a minimum of five Part B DMEPOS client/patient records, surveyors will ask to review Medicare Part C/Advantage records. Using Medicare Part C patients requires that ACHC request an exception from CMS for your pharmacy. CMS regularly runs reports and fact-checks organizations that state they have not submitted Part B DMEPOS claims. If CMS finds that claims were submitted, the survey is put on hold until five client/patient records can be reviewed.

Survey preparation

Review all DMEPOS product codes listed in your application. Are they codes that you actively use? Are there any you want to add or delete? Discuss this with your ACHC Account Advisor if you have questions.

Around the time of your application deposit, ask your billing department or third-party billing vendor to create a list of patients for whom you have billed Medicare B or Medicare Advantage for DMEPOS products in the past 12 months. If there are fewer than five, you may look back over the last 36 months.

Let your surveyor know as soon as the list is available. He or she will quickly review the list to ensure the clients/patients identified meet Medicare Part B requirements.

Because CMS has increased scrutiny over both accrediting organizations and DMEPOS suppliers, it is important to:

  • Review the DMEPOS product codes on your CMS-855S and ACHC application.
  • Test your organization’s ability to run reports on clients/patients BEFORE your unannounced survey to ensure they meet CMS requirements.
  • Work with your billing department or vendor to identify Medicare Part B clients/patients who were issued addendum product codes in the last 12-36 months.
  • Only include Medicare Part C/Advantage records if there are not five Part B records to avoid the need for an exception from CMS.

Taking these steps will help your survey go smoothly and ensure that your pharmacy’s DMEPOS PTAN and ability to bill Medicare remain in good standing.

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