Martha M. Rumore, PharmD, JD, MS, LLM, FAPhA is Of Counsel at Health Law Alliance and a registered U.S. Patent Attorney

Frequently Asked Questions

Federal contractors have made durable medical equipment suppliers a prime target in the post‑pandemic fraud‑and‑abuse crackdown. The National Provider Enrollment (NPE) contractors flag lapsed accreditation, expired surety bonds, and unexpected site visit results as grounds for immediate payment suspension or outright revocation, and a single lapse can freeze cashflow and bar a company from the Medicare program for up to ten years.

Medicare’s enrollment conditions are unforgiving. Every DMEPOS supplier must file the CMS‑855S, secure a $50 000 surety bond for each enrolled location, maintain recognized accreditation, and meet all twenty‑nine supplier standards codified at 42 C.F.R. § 424.57. Failure on any point lets CMS deactivate or revoke billing privileges on the spot. Revocation triggered by a bond lapse is back‑dated to the day the coverage ended, exposing all subsequent claims to overpayment recoupment.

Why revocations are rising

Unannounced site visits routinely uncover locked doors, missing hours‑of‑operation signs, or inventory shortfalls; “administrative” defects that still violate supplier standards and lead to payment suspensions. NPE investigators then load those findings into targeted letters, that stop all Medicare payments until the supplier rebuts the allegations, a process that can take months and be costly for small or large businesses.

Building a compliance‑resistant operation

Successful suppliers treat enrollment carefully. They track the DMEPOS revalidation cycle, align bond renewal dates to avoid coverage gaps, and calendar accreditation surveys twelve months in advance. If you are not a “by appointment only” supplier” you should also check your signage, posted hours, and unlocked public entrance through weekly or biweekly tests, so surprise site visitors cannot fail your business. Your business should also maintain robust electronic compliance efforts, including storing documentation of licenses, all client records mandated by law to be maintained, and delivery or pickup tickets. All of this electronic compliance data should live alongside proof of surety bond coverage, ready for instant upload to PECOS when a contractor asks.

Turn compliance into strategy, not expense

A pristine enrollment record protects your business on multiple fronts: first, it prevents audits that suspend payments; second, it reassures future referral sources, who monitor CMS revocation databases to vet network partners. Finally, it prevents you from the snowball effect of repeated enrollment standards violations. Bond lapses, revoked PTANs, and failed site visits live forever in CMS’s public Preclusion List, and in audit algorithms that steer future auditing scrutiny.

Health Law Alliance offers experienced litigators to defend suppliers when CMS or the NPEs allege non‑compliance.  Whether you need a rapid response to a payment suspension or a corrective action plan in response to a license revocation attempt, speaking with us should be your first step towards regaining control of your business and its Medicare privileges.

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