Prior to 2026 (some industry folks would call that era, “the good old days”), when you started a new DME or opened a branch, it was acceptable and even considered best practices to put together MOCK patient files using the paperwork your company planned on using for consideration and evaluation by the surveyor. Because you had to comply with the CMS Supplier Standards, the new location –be it a brand-new startup company or simply a new branch/location for an existing company—was required to be open for business. But because it was --and is-- typically very difficult to find patients willing to self-pay, and even hard to connect with patients who would accept DMEPOS at no charge, the new company was not expected or required to have actual patients.

New companies would simply put together mock ups of what an actual patient file was going to look like. The mock patient files were required to meet all applicable education and delivery standards with documentation of training, education, delivery, and customer service provided. Patient rights, warranty info, financial responsibilities, home safety assessments (when appropriate) and any other documentation were expected to be present in these files. And the staff that showed the files was expected to be conversant in how the equipment was delivered, set up, explained, and how the paperwork was filled out. Often, the surveyor would ask the staff member to pretend they were setting up equipment and educating a patient and his or her caregivers on the surveyor themselves! These scenarios and acting out were part of the process and a fairly effective way to evaluate the knowledge of the staff regarding not only the equipment, but also the paperwork flow and documentation requirements.

Along came December of 2025 and new, updated guidance from CMS set forth the expectation that mock patient files were not acceptable and that the company had to have actually provided care, treatment, and service to five REAL patient/customers. Frankly, the mock files and role-playing equipment set up procedures had limitations. Surveyors might interview the staff, peppering their questions with “what ifs”, but there’s nothing like the real thing to see how competent and effective the staff and processes are in the real world.

So, the new rule went into place whereby a new organization is required to actually provide care, service, and equipment to REAL patient/customers. Five is the typical number, which allows for a cross section of outcomes and experiences to help the accrediting body evaluate a company’s ability to provide these services. Along with the rule came some challenges. Turns out, it’s a catch-22 trying to find customers. You can’t bill for the services and products because you’re not accredited and don’t have a Medicare provider number. But you can’t get accredited –a condition of participation to obtain a billing number—until you service some customers. New companies and new branches struggle finding these patient/customers. Let’s look at some strategies to comply with this challenging requirement.

How to Fish for Patient/Customers:

• Family & Friends: You can always count on family and friends to help you through life challenges and this challenge is no exception. Countless companies have relied on getting Mom a much-needed walker, or supplying PAP masks and filters to Uncle Joe, or providing diabetic testing supplies to an old friend or neighbor. The family member or friend must have some real need, but one of the good things about our industry is that everybody knows someone who needs DME.
• Talk to Referral Sources: Your business plan most likely includes some referral sources. Doctor’s offices, sleep labs, social work departments in the local hospital, and nursing homes are all great places to find referrals. Check in with whatever referral sources you plan on marketing to and see if they have an uninsured patient that needs DME. While you might have to give them the equipment or supplies at no charge, it’s a great way to establish a relationship with the referral source while solving the problem of finding care for an uninsured patient.
• Community Non-Profits: Think of places like homeless shelters, soup kitchens, and the wide variety of support agencies that are struggling to find care, treatment, and services for their customers. Again, you’ll be helping the community and helping the nonprofit organization, which gets you some credibility and exposure.
• Your Primary Care Doctor: Years ago, my primary care doc figured out what I do for a living. My annual physical always includes a “what’s going on in the DME world” discussion with him. He’s also very curious about things like the face to face requirement, why CMN’s have to be filled out, and what it takes to get a wheelchair covered. Talk to your doctor about your business and explain why you need some patients to serve. He or she and their staff just might have a person or two to send your way.
• Social Media Campaign: This one is tricky, but I’ve seen a few companies actually post on social media that they were looking for some lucky recipients to receive some free care. Be very clear about the type of services you are offering and make it clear that it’s for a limited time only. Make sure you give them a person’s name and number to contact and maintain on line confidentiality at all times.

You’ll want a good cross section of equipment services that covers your equipment list and scope of services. For instance, a full line DME offering complicated respiratory equipment such as oxygen and ventilators, cannot simply provide blood pressure cuffs or walkers. There’s no hard-fast rule on percentages or numbers, but if you are rounding up five patient/customers to service, make sure you cover the more complex equipment in at least one patient file.

Check with payer sources and/or your billing service or billing software support to see about billing for services after you are accredited. Most payer sources have strict regulations regarding how far back you can bill and many forbid you from billing dates prior to accreditation. But it is worth checking to see if that is a possibility with some insurances.

Also, it’s worth checking up front: while most insurances follow Medicare policies regarding un-accredited providers, it is still possible (though unlikely, to be frank) to find entities that will pay you before you are accredited. This might be a long shot, but it would lessen the financial burden of providing free care on your company.

Finally, keep this challenge in perspective. While it is certainly another hurdle in establishing a DME business, it is being implemented across the board and fairly. Thus, ALL new organizations must jump through the same hoops in an effort to open a DME. Once your organization achieves accreditation and gets properly licensed, you’ll be a member of an elite group of business owners providing equipment and services to a customer base that is growing exponentially every day.