Non-exempt DME suppliers must be accredited before they submit the CMS-855S. CMS says the enrollment contractors won't process an application unless the applicant is accredited or exempt, and the contractor manual directs denial of a package that arrives without approved accreditation. The accreditation must also name every product the supplier will bill.
New DME suppliers often assume Medicare enrollment comes first and accreditation follows once they are billing. The rules run the other way. Unless the supplier is exempt, accreditation has to be in hand before the CMS-855S is filed, and an application without it does not get processed.
What do the CMS sources actually say?
Three of them line up:
- The regulation. All suppliers and all their locations "must meet the DMEPOS quality standards and be separately accredited to enroll in and bill Medicare" (42 CFR 424.57(c)(22)(i)).
- The CMS fact sheet. "Except for exempted suppliers listed in the table, you must have DMEPOS supplier-accredited status before submitting your Medicare enrollment application. The NPECs process enrollment applications and verify information but won't process any enrollment application unless the applicant is accredited or exempt" (MLN905710, December 2025).
- The contractor manual. "DMEPOS suppliers must be accredited prior to submitting an application to the contractor. The contractor shall deny any DMEPOS supplier's enrollment application if the enrollment package does not contain an approved accreditation upon receipt" (Program Integrity Manual, chapter 10, section 10.2.5.1).
The 855S builds the same order into its instructions: the supplier "obtains the required National Provider Identification Number (NPI), surety bond and/or accreditation prior to completing and submitting this application." Section 2E2 asks for the accrediting organization's name and the accreditation's effective and expiration dates.
Why can't you bill first and accredit later?
Because Medicare will not pay. "We deny your claims if you aren't accredited by a CMS-approved AO," the fact sheet says, and remittance advice will flag it. An enrolled supplier that fails to maintain accreditation is revoked, according to the manual. There is no grace period built into the rule for a supplier that is enrolled but not yet surveyed.
Why does the product list matter so much?
Accreditation is not a general seal of approval. It "must indicate the specific products and services for which the DMEPOS supplier is accredited in order for the supplier to receive payment for those specific products and services" (424.57(c)(22)(ii)). The 855S product list in section 2E4 and the accreditation's scope have to match. A supplier accredited for respiratory equipment that later adds power mobility must notify its accrediting organization so it "can be re-surveyed and accredited for these new products" (424.57(c)(25)).
Scope also limits which accrediting organization you can use. On the CMS list updated January 9, 2026, the National Association of Boards of Pharmacy is approved for respiratory equipment and a limited set of Appendix C items, but not for wheelchairs, power mobility or custom orthotics and prosthetics. See choosing an accrediting organization.
Why does licensing come even earlier?
Because the accrediting organization checks it. CMS describes the accreditation application stage this way: the AO "reviews your application and documentation (for example, verifies organizational chart and licensure)." A supplier that applies for accreditation before its state license is issued usually waits. Start with the state license requirements for your location and every state you ship to.
Did the 2026 rule change anything about new locations?
Yes. The CY2026 home health final rule (CMS-1828-F, 90 FR 55342, effective January 1, 2026) removed the allowance that let an existing supplier operate a new location for three months before the accrediting organization visited it. MLN905710 now says new locations "must be surveyed before being accredited," and CMS's accreditation Q&A says the AO "will conduct a survey of the new location prior to issuing an accreditation approval," except for statistical sampling of chains with 25 or more locations. Since each location also needs its own 855S, a new branch now follows the same accreditation-first order as a new company. See opening another DME location.
Who is exempt from the accreditation-first rule?
Certain professionals and products. The MLN905710 table lists eligible professionals such as physicians, physician assistants, nurse practitioners, physical and occupational therapists and qualified audiologists; other persons, namely opticians, orthotists and prosthetists; and certain drugs and home health agency supplies. Pharmacies can file an accreditation exemption attestation if they qualify. An exemption from accreditation does not exempt anyone from state licensing, the supplier standards or, for most, the bond. The details are in who is exempt from DMEPOS accreditation.
How do we fit accreditation into the schedule?
Our Accreditation Readiness service ($2,495, see pricing) prepares the policy manual, staff and patient files and a mock survey so you can apply to the accrediting organization of your choice with a scope that matches the products you plan to bill. You apply to the organization yourself and are surveyed unannounced. The Medicare DMEPOS Enrollment Package ($1,295) picks up once accreditation is issued. The enrollment hub lays out the full order.
Common questions
- Can I enroll in Medicare and get accredited later?
- Not as a non-exempt supplier. CMS requires accredited status before you submit the 855S, and claims are denied for suppliers without accreditation from a CMS-approved organization.
- Does accreditation cover every product I sell?
- Only the products and services it names. Under 42 CFR 424.57(c)(22), you are paid only for what the accreditation covers, and new product lines need to be reported to your accrediting organization for survey.
- Can a new branch operate before its accreditation survey?
- Not anymore. From January 1, 2026, the accrediting organization must survey a new location before accrediting it; the old three-month allowance was removed.
- Does an accreditation exemption mean I skip state licensing?
- No. Exemption from accreditation does not change state licensing requirements, the supplier standards or, for most suppliers, the surety bond.
Need Help with Enrollment or Licensing?
We prepare your Medicare enrollment, accreditation survey and state licenses in the order CMS requires, for your official to sign, and track every one to a decision.