Your first DMEPOS survey

Two things changed for new suppliers in 2026

If you enrolled recently, the ground shifted under you in ways that don't apply to shops that have been around a while:

• Surveys are annual and unannounced. Effective January 1, 2026, CMS requires DMEPOS suppliers to be surveyed at least every 12 months, with no scheduled date. You will not get a letter telling you when to be ready.
• Temporary accreditation for new locations is gone. CMS eliminated it — each location must pass a survey before it's accredited, rather than operating on a provisional basis while it waits. For a new shop that means the survey isn't a milestone you grow into; it's a gate you open through.

What first-timers consistently get wrong

Established shops fail surveys through decay — logs that quietly stopped. New shops fail differently, and predictably:

• Policies bought, never localizedA purchased policy template that says you do things you don't actually do is worse than a thin policy that's true. Surveyors compare the manual against how staff really work — mismatches read as a shop that isn't running its own program.
• No history to showA quality-improvement program with zero months of data, an empty complaint log with no process behind it, training files with a hire date and nothing else. New is fine; blank is not. Start the records before the volume arrives.
• The owner-does-everything file gapWhen the owner is also the delivery tech and the biller, personnel records for the owner get skipped. Your own competency documentation counts too.
• Product-specific rules discovered lateOxygen, PAP resupply, power mobility and diabetic supplies each carry documentation rules beyond the general standards. Adding a product line adds requirements the same day — not at the next renewal.
• Delivery paperwork improvised per driverWhatever ticket your first delivery uses tends to become the permanent habit. Make it the right one now — proof of delivery has its own guide, and it's the most-cited area in the program.

The before-you-open checklist

If you're pre-survey — whether you opened last month or you're still enrolling — these are the pieces that should exist on paper before a surveyor could ever walk in:

• Licensure, surety bond, insuranceEvery applicable state license, your $50,000 surety bond, and liability coverage — current, with copies on-site.
• A policy manual that matches realityWritten to your actual product mix and your actual staffing, not a generic binder.
• Delivery ticket templateWith signature, date, item and serial detail, patient-instruction line, and home-safety line already printed on it.
• Complaint log, open and emptyPlus a one-paragraph process saying who takes complaints, who reviews them, and how fast.
• A personnel file per person — including youOrientation, job-specific training, competency check, background screening where required. All signed and dated.
• Beneficiary rights packetPrinted, handed out at every setup, with a signed acknowledgment kept on file.
• Equipment logs startedMaintenance and cleaning tracked by serial number from your very first rental, plus a named person responsible for checking FDA recalls.
• One quality measure being trackedPick something you already care about — delivery errors, callbacks, complaint counts. A single measure with three months of honest data beats an elaborate program with none.

What the first survey actually feels like

Less adversarial than new owners expect, and more specific. A surveyor will tour the space, pull a handful of patient files and trace them end to end, read your logs, talk to whoever is working, and check that what your manual claims is what the shop does. They are not hunting for reasons to shut you down — they're testing whether documentation exists and is current. First surveys go badly mostly when the answer to "can I see that?" is a search rather than a folder.

If findings do come back, they usually arrive with a deadline for a corrective action plan; the response window matters more than the finding. That process is covered here.

This guide is informational only and isn't legal advice or a substitute for your accreditor's standards, the CMS DMEPOS Quality Standards, or 42 CFR 424.57.