The Nationwide Remote Item Delivery Area, Explained

Earlier rounds of Medicare competitive bidding were local. Round 2021 had 130 competitive bidding areas, each with its own bid surety bond, according to CMS in the FY 2027 Inpatient Rehabilitation Facility final rule. Round 2028 uses a different model for every product category in it: a remote item delivery (RID) competitive bidding program with a single nationwide area. CMS created RID programs in the calendar year 2026 home health final rule (CMS-1828-F, 90 FR 55342), and the Competitive Bidding Implementation Contractor (CBIC) confirms that "for Round 2028 of the DMEPOS CBP, CMS will have one nationwide RID CBA that includes all states, territories, and the District of Columbia."

That one sentence changes how a mail-order supplier has to think about licensing, logistics and risk.

What does "remote item delivery" mean in the regulation?

The definitions are in 42 CFR 414.402. A remote item delivery competitive bidding program is one "wherein contract suppliers are responsible for furnishing remote item delivery items under a product category to all Medicare beneficiaries regardless of where they live in the CBA." A remote item delivery item is one "that may be shipped or delivered to a beneficiary's home, regardless of the method of delivery, or picked up at a local pharmacy or supplier storefront if the beneficiary or caregiver for the beneficiary chooses to pick the item up in person."

CBIC adds the policy reason. Each item in a Round 2028 RID program "is already furnished primarily by suppliers from remote locations," and CMS expects to limit RID programs to categories typically furnished from locations "hundreds of miles on average from the beneficiary residence."

Which places are inside the nationwide area?

All 50 states, the District of Columbia and the territories. A CBIC FAQ dated August 27, 2026 names the territories: American Samoa, Guam, the Northern Mariana Islands, Puerto Rico and the U.S. Virgin Islands. There is one area, so there is one competition per product category, not one per metro region.

Which product categories are bid under it?

All seven Round 2028 categories: Class II CGMs and insulin pumps, urological supplies, ostomy supplies, hydrophilic urinary catheters, and off-the-shelf back, knee and upper extremity braces. CBIC says they will be bid "in the same bid window with the same implementation timeline." Details are in the seven Round 2028 product categories.

What does a contract supplier owe patients in a nationwide area?

The obligations do not shrink because the area is large. From CBIC's RID and Contract Supplier Obligations fact sheets:

• Serve everyone in the area. A contract supplier must furnish the competitively bid items to any beneficiary who lives in, or visits, the area and asks for them (42 CFR 414.422(c)). Nationwide, that means anyone.
• Deliver to the home. Under a RID program the supplier must deliver or ship to the beneficiary's home, and may also let a patient or caregiver pick up in person at a pharmacy or supplier location if they prefer.
• Be ready on day one. CBIC's eligibility fact sheet says a contract supplier must be ready to furnish items throughout the area on the first day of the contract period, and only locations listed on the contract may bill for the items.
• Accept assignment. Payment is the single payment amount; the supplier collects the 20 percent coinsurance and any unmet deductible.
• Keep licenses current the whole time. CBIC calls a lapse in required state licensing a breach of contract, which can lead to termination and exclusion from the next round.

How does licensing work when one area covers every state?

This is the part that takes the longest to fix. A bidder must be licensed for each state, DC and territory where it would furnish the items, with every required license current in PECOS by the close of the bid window (CBIC, Licensure for Bidders). The locations on a bid are evaluated together: if a state requires a license, at least one location on the bid must hold it, and CMS says no more than one location is required to satisfy it. A location can also be added to a contract later if it is licensed in at least one state in the area and meets the other enrollment requirements.

State rules vary in ways that matter for a remote supplier. A few examples we have verified from state law:

• Alabama requires an out-of-state provider to keep at least one licensed physical location in Alabama, but its rules exempt a mail order company that ships only by carrier, unless it ships respiratory or oxygen equipment.
• Indiana's statute requires licensed providers to maintain a physical facility and inventory in Indiana (IC 25-26-21-6(b)(2)).
• Tennessee no longer requires an in-state location; an applicant declares at application that it does not want one.
• California registers out-of-state home medical device retailers that supply prescription devices.
• 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)).

Exemptions do not always carry over. CMS's own example: Colorado exempts suppliers in Medicare's National Mail Order Program, but CMS says that exemption does not cover the Round 2028 "Nationwide Remote Item Delivery Program," because the name is different. Our post on the licensing deadline walks through building the list.

Why does the bid surety bond cost more for a RID area?

CMS set the bid surety bond for a RID competitive bidding area at $100,000, the statutory maximum, in the FY 2027 IRF final rule (CMS-1845-F, 91 FR 48982), effective October 1, 2026. Its reasoning was that a RID area "can span multiple States and serve beneficiaries across a vast geographic footprint." The trade-off is that one bond covers every RID bid a bidder submits, where Round 2021 needed a separate bond in each of its 130 areas. Non-RID competitions in future rounds stay at $50,000. The bond comes from a surety on the Treasury's certified list, through your own agent.

Can a contract supplier use subcontractors to reach every state?

Only for limited tasks. CBIC's subcontracting fact sheet allows subcontractors to purchase inventory, deliver items and provide setup or instructions, and maintain or repair rented equipment. Intake and assessment, coordinating care with the physician, submitting claims, ownership of the equipment and product safety cannot be subcontracted. Both the contract supplier and any subcontractor must hold the applicable state licenses, and a subcontractor that sets up equipment or instructs patients must be accredited unless an exemption applies. Contract suppliers report each subcontracting relationship in Connexion within 10 business days.

Does a contract guarantee any volume?

No. CBIC's Contract Supplier Obligations fact sheet says plainly that contract suppliers "are not guaranteed a minimum amount of business." Patients choose among contract suppliers, and CMS may add contracts after award if demand is not being met (42 CFR 414.414(i)). Contract suppliers also file a semi-annual report (Form C) in Connexion within 10 business days after January 1 and July 1, listing the manufacturers and models they offer, and must furnish beneficiaries the same items they make available to other customers (414.422(c)). If a physician orders a specific brand or mode of delivery to avoid an adverse outcome, the contract supplier must furnish it, work with the physician on an alternative, or help the patient find a contract supplier that has it (414.420(b)).

Who is most affected by the switch?

Suppliers that already ship nationally but have only ever licensed the states where they have a building, and regional suppliers that have relied on local competition. For both, the question is no longer which metro areas to bid. It is whether the company, alone or as part of a small supplier network, can show a license for every state that requires one by March 10, 2027, the current target close of the bid window. See networks for small suppliers if you cannot.

How do we help with a nationwide footprint?

Our Remote Delivery Licensing Package covers 10 states for $4,995, and the Nationwide Licensing Package covers every licensing state for $9,995; state fees are paid by you directly. We map which states require a license for the products you ship, prepare each application and attachment for your owner or officer to sign, track the boards, and prepare the 855S change of information so the licenses appear in PECOS. We do not sell bonds or equipment, and no one can promise a contract. A $149 Readiness Review is the place to start, and the state requirements index shows what we have verified.