Every State License in PECOS by the Close of the Bid Window

Round 2028 has one rule that decides more bids than price does. Under section 1847(b)(2)(A)(v) of the Social Security Act, a bidder must meet applicable state licensing requirements, and CMS applies it this way in its Licensure for Bidders fact sheet: "all required licenses must be current and non-expired in the Provider Enrollment, Chain, and Ownership System (PECOS) by the close of the bid window." Because Round 2028 has one nationwide remote item delivery area, "required" can mean dozens of states and territories.

CMS's timeline, updated October 7, 2026, puts the close of the bid window at March 10, 2027, a target date. Working back from that date is the only safe way to plan.

What exactly does CMS check, and when?

According to CBIC, during bid evaluation CMS verifies licenses "through PECOS," confirming that "each of your supplier locations (identified by a Provider Transaction Access Number (PTAN)) listed on your bid meets all applicable requirements for all items in the product category you are bidding on." Four details follow from that:

• PECOS is the record. A license sitting in a drawer, or approved by a state but never reported to your enrollment contractor, does not count.
• It is item by item. The license has to cover every item in the category, lead and non-lead.
• Expiration matters. CMS's July 15, 2026 notice says that if a license "is current but could expire before the bid window closes, you must renew it and have the updated dates entered in PECOS before the close of the bid window."
• It does not end at the bid. Licenses must stay current in PECOS through bid evaluation and, for contract suppliers, the whole contract period.

Does every location need every license?

No. CBIC's FAQ says "all locations included in a bid must together meet the applicable state and local licensing requirements," and "if a state requires a specific license, at least one location included on the bid must hold that license, but no more than one location is required to satisfy that requirement." A supplier with a warehouse in the East and one in the West can split the licensing between them, as long as each license is attached to a PTAN that is on the bid.

Small suppliers (annual gross revenue of $3.5 million or less) that cannot cover every state alone can bid as a network, where member locations collectively meet the licensing requirement (42 CFR 414.418). See networks for small suppliers.

Which states cause the most trouble for remote suppliers?

States regulate DME suppliers in very different ways, and the differences matter most to a company shipping from far away. These are rules we have read in each state's law:

• States that require a building in the state. Alabama has required out-of-state providers to keep at least one licensed physical location in Alabama since June 1, 2014, though a carrier-only mail order company is exempt unless it ships oxygen or respiratory equipment. Indiana's statute requires a physical facility and inventory in Indiana (IC 25-26-21-6(b)(2)). Neither can be solved with paperwork alone.
• States that license out-of-state suppliers directly. North Carolina's statute covers every place, in the state or out of it, that delivers medical equipment to users in North Carolina, with an annual permit. Virginia registers nonresident suppliers that ship oxygen, prescription-only devices, syringes and certain solutions to Virginia consumers. California registers out-of-state home medical device retailers that supply prescription devices, at $280 a year as of July 23, 2026.
• States where the out-of-state route is narrow. Georgia's rule reaches Medicare-enrolled out-of-state manufacturers and wholesale distributors, and the board's 2024 application says an out-of-state applicant not licensed as a manufacturer or wholesaler does not qualify for the out-of-state permit. Ask the board how that applies to you before you assume either answer.
• States that dropped a location rule. Tennessee licenses home medical equipment providers serving Tennessee residents but no longer requires a Tennessee location; the annual fee is $1,404.
• States with exemptions for certain supplies. Florida does not require an HME license for a location that supplies only diabetic monitors and disposable supplies, such as diabetic, ostomy, urological and wound care supplies (Fla. Admin. Code 59A-25.002(2)). Illinois exempts providers accredited under home care standards by a recognized body, and its licensing Act is scheduled for repeal January 1, 2028.
• States with no general DME license. Texas has no general license for DME suppliers, though product-specific rules (drugs, oxygen, orthotics and prosthetics) can still apply.

Our state requirements index lists what we have verified and marks what we have not. Never rely on a national count of "licensing states" from an online list; the ones we checked contradict state law.

How should the licensure database be used?

The National Provider Enrollment contractors (NPEAST and NPWEST) each publish a DMEPOS licensure database by state and product category. CMS calls it "a guide only" and puts the responsibility on the bidder. Its August 27, 2026 FAQs stress the Notes section, which may list exemptions, conditions under which a requirement is waived, and whether the business or an individual must hold the license. CMS's own example of a misreading: Colorado exempts suppliers in Medicare's National Mail Order Program, but that exemption names a specific program, so it does not cover Round 2028's Nationwide Remote Item Delivery Program. When the database and Notes still leave a question, CMS says to contact the state licensing board or your enrollment contractor directly. On October 7, 2026, CMS said it is also building a centralized licensure resource, to be posted on the CBIC site before bidder registration opens.

When does each step need to happen?

Getting a license into PECOS is three steps, and each takes time you do not control:

1. The state application. Some boards inspect first, some require a designated representative or exemptee, and some meet on a schedule. Alabama and Indiana need a physical location before anything else.
2. Issuance. The state issues the license or registration, and you need the license number and dates.
3. The PECOS update. The new license is reported to your enrollment contractor on a CMS-855S change of information and appears in PECOS after the contractor processes it. Our post on getting state licenses into PECOS covers the mechanics.

Counting back from March 10, 2027, a supplier starting from scratch in several states has very little slack. If you are not already working on the states that need a location or an inspection, start there.

Can a bid be fixed after the window closes?

Not for licensing. CBIC's August 27, 2026 FAQ says that if CMS finds during bid evaluation that a supplier "does not meet all applicable state and territory licensure requirements for the nationwide remote item delivery competitive bidding area, the supplier will not be eligible to be awarded a contract." After award, a licensing lapse is a breach that can lead to termination. The bid surety bond has a rider process for correctable bond defects; licensing does not.

Is this the same as the licensing Medicare already requires?

It sits on top of it. Supplier standard 1 already requires a DMEPOS supplier to be licensed where a state requires licensure to furnish the items (42 CFR 424.57(c)(1)(ii)), and CMS's accreditation fact sheet lists not being appropriately licensed as a ground to deny or revoke enrollment. Competitive bidding adds a hard date and checks the whole nationwide footprint at once. See mail-order DME and the states you ship to for the everyday version of the rule.

Who does the work, and who signs?

We prepare each state application and every attachment, track the board, and answer deficiency letters. Your owner or officer signs each application and pays each state fee directly; where a state uses an online portal, the account stays yours. For the PECOS step, we prepare the 855S change of information and, once your authorized official approves us as a PECOS surrogate, enter it for your official to sign. Pricing is on our pricing page: $699 per state ($899 for California, Florida, Georgia and Alabama), $4,995 for a 10-state Remote Delivery Licensing Package, $9,995 for the Nationwide Licensing Package, and $299 per license, per year for renewal tracking so nothing expires mid-contract. No one can promise a license by a date, which is why the work has to start now.