Unless you’ve been on a remote island somewhere for the last nine or ten months, you probably are aware that the accreditation process has changed dramatically since this time last year. And you are most likely aware that the cornerstone of the accreditation process—that is, the triennial survey—is going to become a thing of the past. The survey, which up to this point has traditionally been done once every three years, is set to become an annual visit going forward. There is still a bit of misunderstanding in the industry about how the annual visit will be implemented for existing companies, and ongoing confusion about the nature and timing of the annual visits for new, startup companies as well. 

The change to annual visits went into effect on January 1, 2026. This was a directive from Medicare/CMS and has been implemented across the board at all accrediting agencies with official deeming status. If you were or will be surveyed at any point during 2026, you’re on the annual cycle right away and will be revisited in 2027. If you were visited in 2024, you are on a three-year cycle until 2027, then you will be on the annual cycle. If you were visited in 2025, you are on the three-year cycle until 2028, then you will on the annual cycle.

By the end of 2028, all accredited DMEPOS providers will have been transitioned over to an annual cycle. Of course, there are exceptions. If a survey visit is triggered by some change in your business (for instance, a change of ownership, adding a new branch, or change of address), you will receive that visit and be transitioned to the annual visit protocol going forward.

Some of the core rules regarding accreditation in general and survey/inspections specifically are in place as always. Other rules have been modified a bit. There are no “blackout dates” and scheduling for the survey visits must be done on an absolutely unannounced basis. DME organizations are expected to be ready and available for survey during normal business hours. For new organizations (and new branches as well), there is no provisional accreditation. You are expected to be in full compliance with the standards and up and running prior to survey so that the surveyor can properly and completely assess your compliance with the standards.

These changes were made by CMS to prevent fraud, waste, and abuse. The belief is that annual visits with the obvious increased scrutiny and accountability will decrease the fraud, waste, and abuse. Certainly, bad actors in the industry will have a harder time taking advantage of the system because of this increased scrutiny and more frequent inspections. Folks who are doing the right things have even more incentive than before to be “on their toes” with regards to compliance.

There is no way to avoid the fact that these changes will cost the accredited organizations more money. The logistics of annual visits as opposed to triennial visits costs more to implement and perform. So, is there any added value to this increase in scrutiny and cost? The answer is an emphatic “YES”. To get more out of your accreditation and survey process, I suggest:

• Think of accreditation as a continuous process, not an annual event. One of the cornerstones of accreditation is continuous quality improvement (CQI). Embrace that CQI and incorporate the philosophy into your corporate culture.
• Increase internal surveillance activities. Think about more self-audits. Those mock surveys you did every three years should be done at least annually. Activities you were doing annually: maybe consider doing them a couple times each year.
• Make sure all staff members are prepared for survey. Don’t simply rely on a point person in charge of accreditation. Staff needs to be aware and actively involved in the preparation for survey and the survey itself. If you rely on one “point person”, what happens if they are not available the day of the survey?
• Review and update policies & procedures annually. This ensures you are continuously ready for survey.

The key to success is consistency. Think about this: With triennial visits, the surveyor is reviewing patient charts and personnel files once every three years. In the DME industry, both patient and staff turn over at somewhat frequent rates. Chances are--with a triennial visit--that the patients and staff whose files are being reviewed are new. Annual visits increase the chances that your surveyor will be looking at some of the same patient and employee records as they looked at during the last visit. Consistently conducting follow up visits and obtaining renewal orders for a given patient or documenting annual in-service education or competency assessment for a given employee becomes more important because of this increased scrutiny.

The same goes for documentation of sentinel events, complaint resolution, and quality improvement activities. Consistent follow up compliant with law and regulation as well as the accreditation standards will help ensure a positive outcome for every survey.

If you respond to this increased scrutiny and accountability with increased vigilance, more frequent education, and more aggressive self-audit activities, you can improve your business operationally and decrease the chances for deficiencies when the surveyor shows up.