CMS exempts certain professionals from DMEPOS accreditation, including physicians, physician assistants, nurse practitioners, physical and occupational therapists, audiologists, opticians, orthotists and prosthetists, plus drug-only product lines. Pharmacies may qualify through an attestation. Exempt suppliers still enroll on the 855S, meet the supplier standards and state licensing rules, and usually post the surety bond.
Accreditation is the default for Medicare DME suppliers: every supplier and location must "be separately accredited to enroll in and bill Medicare" (42 CFR 424.57(c)(22)). The exceptions come from section 154(b) of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), which CMS summarizes in its fact sheet MLN905710 (December 2025). They are narrower than many practices assume, and an exemption from accreditation is not an exemption from anything else.
Which professionals are exempt?
MLN905710 lists two groups. The first is "eligible professionals":
- certified nurse-midwife
- certified registered nurse anesthetist
- clinical nurse specialist
- clinical psychologist
- clinical social worker
- nurse practitioner
- nutritional professional and registered dietitian
- occupational therapist
- physical therapist
- physician
- physician assistant
- qualified audiologist
- qualified speech-language pathologist
The second is "other persons": opticians, orthotists and prosthetists. The CMS Program Integrity Manual's version of the list (chapter 10, section 10.2.5.1) also names optometrists, and says group practices of the exempt practitioner types are covered too.
The exemption applies "unless we determine the quality standards specifically apply to them," and MIPPA lets CMS exempt others based on licensing or other quality requirements, but CMS says it "don't currently use this statutory authority." No other supplier type is exempt by status.
Which products never need accreditation?
MLN905710 lists DME drugs (inhalation drugs and DME pump-infused drugs), home health agencies' medical supplies, and other Part B drugs such as immunosuppressive and antiemetic drugs. Section 2E3 of the CMS-855S lists the "non-accredited products" a supplier can check: epoetin, immunosuppressive drugs, infusion drugs, nebulizer drugs, oral anticancer drugs and oral antiemetic drugs.
The manual draws the line that catches suppliers: "Although suppliers that provide only drugs and pharmaceuticals are exempt from the accreditation requirement, suppliers that provide equipment to administer drugs or pharmaceuticals must be accredited." A pharmacy that dispenses nebulizer drugs needs no accreditation for them; the same pharmacy supplying the nebulizer does.
Where do pharmacies fit?
Pharmacies are not on the professional list. "Pharmacies may also apply for an accreditation exemption by submitting an accreditation exemption attestation to the NPECs" (MLN905710), and the 855S has two pharmacy boxes: a previously enrolled pharmacy with an attestation on file, and a pharmacy providing only non-accredited products. The attestation has its own eligibility tests; see the pharmacy accreditation exemption attestation.
What does an exempt supplier still need?
Almost everything else. CMS's fact sheet on exemptions changes only the accreditation step.
- Medicare enrollment on the CMS-855S for each location, with the $750 application fee for 2026, and screening. Section 2E2 is where you claim the exemption based on supplier type.
- The supplier standards. All 30 standards in 424.57(c) apply, though some have practitioner exceptions: physicians and PT or OT practices furnishing items to their own patients are excepted from the 30-hours-a-week rule and the ban on sharing a practice location, and custom O&P personnel in private practice are excepted from the 200-square-foot minimum.
- The surety bond, unless the supplier fits a bond exception in 424.57(d)(15). Those exceptions are tighter than the accreditation list: physicians and nonphysician practitioners only when items go to their own patients as part of their professional service; PT and OT practices only if solely owned, furnishing to their own patients and billing only orthotics, prosthetics and supplies; O&P personnel only if state-licensed, solely owned and making custom items. See the DMEPOS surety bond.
- State licenses. Standard 1 still requires any license a state imposes for the items you furnish. Check the state requirements for your products.
- Liability insurance of at least $300,000, and the 30-day change-reporting rule.
Which common situations lose the exemption?
- A practice that opens a separate DME company. An LLC owned by physicians is not a physician. If it enrolls as a medical supply company, it needs accreditation.
- Selling beyond your own patients. Several practitioner exceptions in the supplier standards and the bond rule depend on furnishing items to your own patients as part of your professional service.
- Adding equipment to a drug-only line, as with infusion pumps or nebulizers.
- A reactivation. The manual says a non-exempt supplier "requesting reactivation after a deactivation (regardless of the deactivation reason) is required to be accredited."
Is an exempt supplier ever surveyed?
Not by an accrediting organization, unless it chooses accreditation voluntarily. It still gets the enrollment site visit and must permit inspections under standard 8. For practices weighing whether to supply equipment at all, our post on when a physician practice supplies DME covers the business side, and O&P practitioner and facility licensing covers the state side for orthotists and prosthetists.
How do we confirm an exemption before you file?
The $149 DMEPOS Readiness Review checks your supplier type, ownership structure and product list against the exemption tables and the bond exceptions, so the 855S claims only the exemptions you qualify for. If you do need accreditation, Accreditation Readiness is $2,495. The Medicare DMEPOS Enrollment Package, $1,295, covers the 855S either way; your authorized official signs it.
Common questions
- Do physicians need DMEPOS accreditation to supply equipment?
- No. Physicians are on CMS's list of exempt eligible professionals. They still enroll on the CMS-855S and meet the supplier standards, and the bond exception applies only when items go to their own patients as part of their service.
- Are orthotists and prosthetists exempt from accreditation?
- Yes, CMS lists orthotists and prosthetists as exempt persons. The exemption is for the professionals themselves. A company enrolling as a medical supply company with O&P personnel is a different supplier type, so confirm its status before claiming the exemption on the 855S.
- Does a pharmacy need accreditation to bill nebulizer drugs?
- No. Drug-only product lines such as nebulizer drugs are exempt. Supplying the nebulizer itself, or any equipment to administer a drug, requires accreditation unless the pharmacy qualifies for the attestation exemption.
- Does an accreditation exemption also exempt me from the surety bond?
- Not necessarily. The bond exceptions in 42 CFR 424.57(d)(15) are narrower and depend on ownership, whose patients you serve and what you bill. Pharmacies are not exempt from the bond.
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