For O&P practices, supplier enrollment standards have been viewed as a standard requirement and part of being a Medicare supplier. The process was addressed during initial Medicare enrollment or revalidation and revisited every three years. Effective January 1, Medicare supplier site visits will now occur annually, signaling a significant shift in how compliance is monitored and enforced.
While the Medicare supplier standards themselves are not new, how they are being enforced has changed dramatically. Designed to strengthen program integrity, the increase in site visit frequency is intended to reduce fraud and abuse and protect Medicare beneficiaries.
Under the new schedule, inspectors will conduct annual unannounced visits to ensure practices remain compliant with the Medicare Supplier Standards.
This reflects a broader expectation from Medicare: Enrollment information must accurately reflect operational reality every single day, not just at the time of enrollment or revalidation.
Importantly, this transition will not occur overnight for every provider. CMS is honoring existing three-year enrollment cycles until they expire.
For example, if a supplier’s current enrollment extends through the end of 2027, that enrollment will be honored through its expiration date. Once it expires, the supplier will move onto the annual site visit cycle. New Medicare suppliers, however, should expect annual surveys from the beginning, making compliance readiness critical.
Preparing for annual unannounced visits requires a fundamental shift in mindset. Compliance can no longer be something practices prepare for every few years. Instead, O&P providers must operate in a perpetual state of readiness, with constant attention to documentation accuracy, staff training, facility standards, and enrollment alignment.
For example, outdated posted hours, missing signage, or unmanned offices can result in deactivation or revocation of billing privileges.
What do you do if your office hours are posted as 8 a.m. to 5 p.m. but your administrative assistant called out for the day, and your practitioner is at an off-site call? If the doors are locked, but your posted hours say you’re open, you need to post a change to the office hours or get someone to cover that office. If not, the result could be devastating for your business.
Perhaps the most consequential aspect of this change is the direct connection between supplier enrollment compliance and business continuity. A revoked or deactivated Medicare number can delay claims, abruptly stop revenue, disrupt patient care, and strain referral and hospital relationships.
Reinstatement can take months, and retroactive billing is never guaranteed. For practices operating in an already challenging reimbursement environment, even short-term disruption can have lasting financial consequences.
For successful O&P practices, supplier enrollment can no longer be treated as an administrative afterthought. Regular internal compliance reviews, proactive updates to enrollment records, and ongoing staff education are now essential components of a well-run organization. Any business change—whether it involves new locations, ownership updates, changes in hours, or service expansions—should immediately trigger a supplier enrollment review.
Ultimately, supplier enrollment standards are no longer just a regulatory requirement. They are a core issue for risk management and business sustainability. Practices that embrace continuous compliance will be better positioned to protect revenue, maintain patient access, and thrive in an increasingly regulated healthcare environment.
Supplier enrollment compliance doesn’t end with understanding the rules—it requires knowing how to pass an unannounced Medicare site visit with confidence.
Erin Cammarata is president and owner of CBS Medical Billing and Consulting. She can be contacted at erin@cbsmedicalbilling.com.
For more information and to download a Medicare visit checklist, visit cbsmedicalbilling.com/dmepos-compliance-checklist.
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