Every year, I see practices scrambling because an accreditation deadline was missed, a Medicare enrollment issue wasn’t addressed, a license expired, or a new prior authorization requirement caught the team by surprise.
Most of these situations have one thing in common: They were preventable.
Compliance shouldn’t be managed by memory, and it shouldn’t begin when an audit letter, surveyor, denial, or revalidation notice arrives.
As we close out 2026, now is the time to build your 2027 O&P compliance calendar. Here are five areas every practice should address in building theirs.
1. Know Your Accreditation Date
Your accreditation date is especially important heading into 2027.
CMS has changed DMEPOS accreditation from the previous three-year resurvey and reaccreditation cycle to at least once every 12 months. Suppliers accredited before January 1, 2026, transition to the annual cycle when their existing three-year accreditation period expires.
Don’t assume you know when your next survey or reaccreditation is due. Contact your accrediting organization, confirm your date, and put reminders on your calendar well in advance.
More importantly, don’t wait for the survey to become compliant. Your practice should be survey-ready every day.
2. Protect Your Medicare Enrollment and PTAN
When was the last time you reviewed your Medicare enrollment information? DMEPOS suppliers generally revalidate Medicare enrollment every three years, but revalidation isn’t the only thing to watch.
CMS may deactivate Medicare billing privileges when a provider or supplier has not submitted a Medicare claim for six consecutive calendar months. This can easily become an issue for an O&P practice that maintains a PTAN for a location or business segment that doesn’t frequently see Medicare patients.
Review every PTAN associated with your organization. Is it active? When was the last Medicare claim submitted? Are your locations, ownership, and other enrollment information current?
3. Check Your Prior Authorization Documentation
Prior authorization continues to expand so make sure authorization checklists are up to date. Medicare expanded required prior authorization for several O&P codes during 2026, including additional spinal, knee, and ankle-foot orthoses. Practices should make sure those changes have actually made their way into their intake, documentation, and authorization workflows.
More changes are coming too—phased implementation for upper-limb orthosis codes L-3761 and L-3916 continues in 2027. Phase two begins January 26, 2027, expanding the requirement to additional states, and on April 26, 2027, the requirement becomes nationwide.
There are also separate face-to-face encounter and Written Order Prior to Delivery requirements that expanded in late 2026, and new probationary prior authorization requirements that may affect certain newly enrolled suppliers and ownership changes.
The takeaway is simple: Don’t rely on last year’s authorization workflow to get you through a new year.
4. Schedule Your Coding and Reimbursement Reviews
CMS publishes HCPCS updates throughout the year, and applicable DMEPOS fee schedule updates may also occur quarterly.
Put quarterly reviews on your calendar. Don’t simply ask, “Did a code change?” Ask whether your system was updated correctly, whether your fee schedules are current, whether payer requirements changed, and whether staff need additional education.
A regulatory update doesn’t help you if no one uses it.
5. Give Things Without Deadlines a Deadline
Some of the most important compliance responsibilities won’t arrive with a CMS reminder. State licenses, professional credentials, surety bonds, liability insurance, payer credentialing, employee training, HIPAA compliance, internal documentation and coding audits, and policies and standard operating procedures all must be updated regularly and don’t always come with reminders.
Put them on the calendar anyway and be sure to put a person’s name next to every responsibility.
Because a deadline that “everyone” is responsible for often becomes a deadline no one is responsible for.
Before January arrives, build one centralized compliance calendar with your deadlines, responsible person, and 30- and 60-day reminders.
Compliance shouldn’t begin when the audit letter arrives.
Want the Complete Calendar?
CBS Medical Billing & Consulting has created a complimentary 2027 O&P Compliance Calendar. Scan the QR code to download your copy.
Regulatory information is current as of September 24, 2026. CMS requirements and implementation dates are subject to change. Practices should verify current requirements with CMS, their DME MAC, accrediting organization, and applicable payers.
Erin Cammarata is president and owner of CBS Medical Billing and Consulting. She can be contacted at erin@cbsmedicalbilling.com.
