DMEPOS Enrollment for Pharmacies

Pharmacies are one of the largest groups of DMEPOS suppliers. Many sell diabetic testing supplies, nebulizers and inhalation drugs, compression products or mobility aids, and bill Medicare Part B for them through the DME MACs. To do that, the pharmacy enrolls as a DMEPOS supplier on the CMS-855S, where "Pharmacy" is one of the listed supplier types, and meets the same 30 supplier standards as any other supplier. The differences are in accreditation, in how CMS treated pharmacies during the 2026 moratorium, and in state law.

Does a pharmacy have to be accredited?

It depends on what it supplies and whether it qualifies for the pharmacy exemption. CMS's MLN905710 fact sheet says "pharmacies may also apply for an accreditation exemption by submitting an accreditation exemption attestation to the NPECs," the National Provider Enrollment contractors. The CMS-855S accreditation section gives a pharmacy two exemption options to check: the location is a "previously enrolled pharmacy with attestation on file," or the supplier "is a pharmacy providing only non-accredited products." Products that do not require accreditation, listed on the form, include epoetin, immunosuppressive drugs, infusion drugs, nebulizer drugs, oral anticancer drugs and oral antiemetic drugs. The eligibility criteria for the attestation are covered in the pharmacy accreditation exemption attestation.

A pharmacy that does not qualify, or that supplies items outside the exemption, needs accreditation from a CMS-approved accrediting organization before the enrollment contractor will process its application, and since January 1, 2026, a resurvey at least every 12 months (42 CFR 424.57(c)(24)). The National Association of Boards of Pharmacy is one of the approved organizations, but its CMS-approved scope is limited; check that it covers your products before choosing it. See choosing an accrediting organization.

Is a pharmacy exempt from the surety bond?

No. The exceptions to the $50,000 DMEPOS bond in 42 CFR 424.57(d)(15) cover government-operated suppliers with a comparable state bond, solely owned O&P practitioners billing only O&P and supplies, physicians and nonphysician practitioners furnishing items to their own patients, and solely owned physical and occupational therapy practices billing only orthotics, prosthetics and supplies. Pharmacies are not on the list. A pharmacy enrolling, revalidating or adding a location posts the bond like anyone else. See the DMEPOS surety bond.

Which supplier standards trip up pharmacies?

• Sharing space. A DMEPOS supplier may not share a practice location with another Medicare supplier or provider, except in narrow cases, including a DMEPOS supplier co-located with and owned by an enrolled Medicare provider and operated as a separate unit (424.57(c)(29)). A pharmacy inside a clinic should check this before filing.
• "Closed door" pharmacies. The location standard expressly allows a "closed door" business "such as a pharmacy or supplier providing services only to beneficiaries residing in a nursing home," as long as it meets every other location requirement (424.57(c)(7)(iii)).
• Hours. The location must be open to the public at least 30 hours a week (424.57(c)(30)), with the hours posted.
• Insurance. At least $300,000 in comprehensive liability coverage. The 855S says professional and malpractice insurance "is not the same as comprehensive liability insurance." See insurance requirements.
• Changes in 30 days. A new pharmacist in charge does not change Medicare enrollment by itself, but changes in ownership, managing employees, location or products must be reported within 30 days (424.57(c)(2)).

Did the 2026 moratorium affect pharmacies?

Generally not. The moratorium on new medical supply companies (February 27 to August 27, 2026) covered seven medical supply company types, including "medical supply company with registered pharmacist." CMS said a pharmacy's principal function "is typically not the provision of DMEPOS" but "the dispensing of medicines," so the moratorium "would generally not apply," and that pharmacies remained able to open new locations. A business that is really a mail-order medical supply company with a pharmacist on staff is a different matter; CMS warned that enrolling under the wrong type to avoid a moratorium can bring a reenrollment bar of up to 10 years. See the 2026 moratorium.

Can a pharmacy bid in Round 2028 using its exemption?

No. CBIC's July 2026 notice says "accreditation exemptions do not apply to the DMEPOS CBP. All pharmacies must be accredited to be eligible, regardless of any general exemptions." CBIC's subcontracting fact sheet notes that the pharmacy exemption still applies to a pharmacy working as a subcontractor (for example, delivering and instructing), but not to a pharmacy that bids. A pharmacy that wants a Round 2028 contract for CGMs, insulin pumps or other categories needs accreditation for every lead and non-lead item in the category, plus every required state license in PECOS, by the close of the bid window (currently targeted for March 10, 2027). Patients can still pick up remote item delivery items in person at a local pharmacy if they choose, under the RID rules. See Round 2028.

How does state law treat pharmacies that supply DME?

Many state DME licensing laws exempt pharmacies, because the board of pharmacy already regulates them, but the details differ:

• Florida exempts pharmacies licensed under chapter 465 from its home medical equipment provider license, unless they run a separate company or division in the HME business (Fla. Stat. 400.93(5)). See Florida.
• California exempts pharmacies from the CDPH home medical device retailer license because the Board of Pharmacy regulates them. See California.
• Ohio exempts pharmacies that do not sell or rent home medical equipment, or that receive less than $10,000 a year from it, from its HME license (Ohio Rev. Code 4752.02(B)). See Ohio.
• Georgia exempts pharmacies from its DME supplier license unless they run a separate DME business. See Georgia.

An out-of-state pharmacy mailing DME may need the destination state's nonresident pharmacy license for drugs and, separately, a DME or device license or registration for the equipment. Check both.

What about plans and network managers?

Some health plans route DME through managers that include pharmacies. Blue Cross Blue Shield of Michigan's April 2026 FAQ lists "pharmacy providers who distribute or dispense DMEPOS" among the provider types Northwood manages, and says its Medicare Advantage members must get CGM products from a participating network pharmacy for dates of service on or after October 1, 2024. See DMEPOS network managers.

How do we help pharmacies with DMEPOS enrollment?

We prepare the 855S, the exemption attestation or accreditation documents, and the bond and insurance documents for your agents, and, once your authorized official approves us as a PECOS surrogate, enter and submit the application for your official to sign. The Medicare DMEPOS Enrollment Package is $1,295 for the first location and $595 for each additional location; Accreditation Readiness is $2,495 if you need or want accreditation (for example, to bid); state DME licenses are $699 each ($899 in California, Florida, Georgia and Alabama). You pay the CMS fee, state fees and bond premium directly. We do not sell bonds, and no one can promise enrollment.