If you live in Georgia and you've used Medicare durable medical equipment (DME), prosthetics, orthotics, or supplies — oxygen, CPAP/BiPAP, power wheelchairs, hospital beds, walkers, diabetic testing supplies, wound care, lymphedema compression items, prosthetic limbs, orthotic braces, or any number of other items — you've been touched, directly or indirectly, by the Medicare DMEPOS Competitive Bidding Program (CBP). Between 2011 and 2024, the CBP changed which suppliers could serve Medicare beneficiaries in Atlanta, what those suppliers were paid, what your coinsurance looked like, and in some cases whether your preferred supplier could still bill Medicare on your behalf.
The CBP was authorized by Section 302 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (the MMA, Public Law 108-173, signed December 8, 2003 by President George W. Bush). It is codified at Section 1847 of the Social Security Act. The implementing regulations are at 42 CFR Part 414 Subpart F. The premise was simple: Medicare's historical DMEPOS fee schedule was based on supplier charges from the 1980s and bore little relationship to current market prices. The CBP would let Medicare-enrolled, accredited DMEPOS suppliers submit bids for specific product categories in specific Competitive Bidding Areas (CBAs). CMS would calculate Single Payment Amounts (SPAs) from those bids and award contracts to selected suppliers.
Implementation took years. After a halted initial round (delayed by MIPPA 2008, Public Law 110-275, July 15, 2008), the program rolled out across a series of rounds: Round 1 Rebid (January 1, 2011) in 9 CBAs, Round 2 (July 1, 2013) in 91 CBAs including the Atlanta-Sandy Springs-Marietta GA MSA, National Mail-Order for Diabetic Testing Supplies (July 1, 2013), Round 1 and 2 Recompete (January 1, 2017), and Round 2021 — which CMS ultimately implemented for only two product categories (off-the-shelf back braces and off-the-shelf knee braces) after concluding that bids in other categories did not meet program statutory targets.
Effective January 1, 2024, most DMEPOS categories returned to fee schedule pricing as the Round 2021 contracts for non-implemented categories expired. CMS is actively studying the future structure of the CBP through rulemaking. Off-the-shelf back and knee braces remained under Round 2021 limited contracts through their term.
For Georgia beneficiaries today, the practical picture is:
- Most DMEPOS items are paid under the fee schedule (no active CBP)
- CGS Administrators is the DME MAC for Jurisdiction C, processing all Georgia DMEPOS claims (including the lymphedema compression items added by the LTA effective January 1, 2024)
- Standard Written Order (SWO) requirements continue
- 20% Part B coinsurance after deductible continues
- Quality Standards and accreditation under Section 1834(a)(20) continue to apply
- Specific LCDs continue to govern coverage criteria
- Future CBP rounds may resume; the framework is statutory and remains intact
This guide explains the CBP statutory framework, the multi-round implementation history, the Atlanta CBA experience, how SPAs were determined, what happened to non-contract suppliers, the quality standards and accreditation requirements that survive across CBP and non-CBP periods, the lead item pricing methodology adopted in the CY 2021 Final Rule, the Round 2021 limited implementation, the current hiatus with fee schedule pricing for most categories, what the future might hold, and how Georgia beneficiaries and suppliers should think about DMEPOS pricing and access today.
This is policy-translator territory. The statute is enacted. The regulations are codified. The implementation history is complex. The current hiatus is real but may not be permanent. Georgia DMEPOS access depends on multiple interacting frameworks — and understanding the CBP is essential for understanding the broader DMEPOS landscape.
Key takeaways
- The DMEPOS Competitive Bidding Program (CBP) was authorized by Section 302 of the MMA (Public Law 108-173, December 8, 2003) and codified at Section 1847 of the Social Security Act.
- Implementing regulations are at 42 CFR Part 414 Subpart F.
- The CBP replaces the historical fee schedule with competitively determined Single Payment Amounts (SPAs) in geographic Competitive Bidding Areas (CBAs) for selected product categories.
- Implementation: Round 1 Rebid 2011 (9 CBAs) → Round 2 2013 (91 CBAs including Atlanta-Sandy Springs-Marietta) → National Mail-Order 2013 (diabetic testing supplies) → Round 1/2 Recompete 2017 → Round 2021 (limited to 2 product categories after bid evaluation).
- Round 2021 limited implementation: CMS implemented contracts only for off-the-shelf back braces and off-the-shelf knee braces, concluding that bids in other categories did not meet statutory savings targets.
- Effective January 1, 2024: Most DMEPOS categories returned to fee schedule pricing as Round 2021 ended for non-implemented categories.
- Quality Standards and accreditation under Section 1834(a)(20) continue to apply across CBP and non-CBP periods.
- Atlanta-Sandy Springs-Marietta MSA is the Georgia CBA; rural Georgia and non-CBA areas have been on fee schedule throughout.
- CGS Administrators is the DME MAC for Jurisdiction C (covering Georgia and 16 other states/territories).
- National Supplier Clearinghouse (NSC) handles DMEPOS supplier enrollment via the CMS-855S application.
- Standard Written Order (SWO) requirements continue; many items also have face-to-face encounter requirements.
- Beneficiary cost-sharing (Part B deductible + 20% coinsurance) continues regardless of CBP/non-CBP status.
- MIPPA 2008 (Public Law 110-275, July 15, 2008) delayed initial Round 1 implementation after early problems.
- Lead item pricing methodology was adopted in the CY 2021 DMEPOS Final Rule.
- The CBP statutory framework is intact; future rounds may resume after CMS rulemaking and bid analyses.
- Lymphedema compression items (new Part B benefit effective January 1, 2024 under the Lymphedema Treatment Act) have their own framework under Section 1861(s)(2)(JJ) and Section 1861(iii), processed by the DME MAC.
Statutory and regulatory framework
Section 302 of the MMA (Public Law 108-173)
- Enacted December 8, 2003
- Established Section 1847 of the Social Security Act
- Authorized CBP for DMEPOS
- Required quality standards and accreditation
- Provided for phased implementation
Section 1847 SSA
The CBP statutory authority. Key provisions:
- Authorizes CBP for selected DMEPOS items in selected geographic areas
- Requires competitive bidding process
- Requires quality standards and accreditation
- Requires beneficiary protections including ombudsman and education
- Establishes statutory savings targets
Section 1834(a)(20) SSA
Quality Standards and accreditation:
- All DMEPOS suppliers (CBP and non-CBP) must meet CMS Supplier Standards
- DMEPOS Quality Standards (originally established 2007)
- Accreditation by CMS-approved accrediting organizations (e.g., ACHC, BOC, CHAP, others)
- Required for enrollment and reenrollment
42 CFR Part 414 Subpart F
Implementing regulations:
- Definitions
- Bid submission process
- Bid evaluation
- Contract supplier selection
- SPA calculation
- Beneficiary protections
- Non-contract supplier rules
- Grandfathering provisions
MIPPA 2008 (Public Law 110-275, July 15, 2008)
- Halted Round 1 after early implementation problems
- Required reforms including beneficiary protections
- Set up Round 1 Rebid
Implementation rounds
Round 1 (2008, halted)
- Initially scheduled to begin July 1, 2008
- Halted by Congress (MIPPA 2008) after July 2008 round implementation problems
- Suspended contracts; required do-over
Round 1 Rebid 2011
- Effective January 1, 2011
- 9 CBAs:
- Charlotte-Gastonia-Concord NC-SC
- Cincinnati-Middletown OH-KY-IN
- Cleveland-Elyria-Mentor OH
- Dallas-Fort Worth-Arlington TX
- Kansas City MO-KS
- Miami-Fort Lauderdale-Pompano Beach FL
- Orlando-Kissimmee FL
- Pittsburgh PA
- Riverside-San Bernardino-Ontario CA
- 9 product categories
- First operational round
Round 2 2013
- Effective July 1, 2013
- 91 CBAs including Atlanta-Sandy Springs-Marietta GA MSA
- 8 product categories
- First Georgia CBA implementation
National Mail-Order 2013
- Effective July 1, 2013
- Diabetic testing supplies (DTS) — strips, lancets, control solution
- National scope (covered all Medicare beneficiaries receiving DTS by mail-order)
Round 1 Recompete 2014
- Effective January 1, 2014
- Round 1 CBAs
- Limited to non-implemented categories
Round 2 Recompete 2017
- Effective July 1, 2016 (initially); January 1, 2017 for some categories
- Round 2 CBAs
- Updated SPAs
Round 1 2017 Recompete
- Effective January 1, 2017
- Round 1 CBAs
- Updated SPAs
Round 2018 (originally planned, became part of Round 2021)
- Originally planned for 2018
- Statutory and regulatory complications
- Most categories consolidated into Round 2021 planning
Round 2021
- Originally planned January 1, 2021
- Delayed by COVID-19 public health emergency
- CMS conducted bid evaluation
- CMS implemented contracts only for:
- Off-the-shelf back braces
- Off-the-shelf knee braces
- CMS concluded bids in other categories did not meet statutory savings targets
- Categories without implemented contracts returned to fee schedule
Current hiatus (January 1, 2024 forward)
- Round 2021 contracts for the two implemented categories continued through their term
- All other DMEPOS categories returned to fee schedule pricing
- CMS studying future CBP structure through rulemaking
- Quality Standards and accreditation continue
Competitive Bidding Areas (CBAs)
Designation
- CMS designated CBAs primarily based on Metropolitan Statistical Areas (MSAs)
- Some CBAs included multiple MSAs
- Population-based eligibility
- Rural areas generally not designated as CBAs
Atlanta-Sandy Springs-Marietta GA CBA
- Designated for Round 2 effective July 1, 2013
- Included 28-county MSA at peak
- Updated CBA boundaries over recompete rounds
- Subject to Round 2 product category bidding
Non-CBA Georgia
- Rural Georgia (much of south Georgia, north Georgia mountains, coastal Georgia outside Savannah MSA) generally non-CBA
- Operated under fee schedule throughout CBP rounds
- Continues under fee schedule
Bid submission and contract supplier selection
Eligibility to bid
- Medicare-enrolled DMEPOS supplier
- Meets Quality Standards
- Accredited by approved accreditor
- Has required surety bond
- Has applicable state license(s)
Bid submission
- Per CBA, per product category
- Bid amount for each HCPCS code in category
- Quality standards self-attestation
- Financial documentation
Bid evaluation
- CMS evaluates composite bids against budget-neutral target
- Capacity assessment (supplier ability to serve CBA)
- Quality standards verification
- Financial responsibility verification
Single Payment Amount (SPA)
- Median (or other CMS-specified statistic) of winning bids
- Single price across CBA for all contract suppliers
- Different SPA for each HCPCS code
Lead item pricing methodology (CY 2021 Final Rule)
- Adopted in the CY 2021 DMEPOS Final Rule
- Designated lead items in each product category
- Pricing for non-lead items derived from lead item pricing
- Intended to reduce bidding burden and improve consistency
Contract award
- CMS awards contracts to suppliers whose composite bids fall below pivotal bid
- Contract period typically 3 years
- Performance monitoring throughout contract
Effect on non-contract suppliers
General rule
- Non-contract suppliers generally cannot bill Medicare for items in CBP categories in a CBA
- Exception: certain grandfathered situations
Grandfathering
- Rental items: existing rental arrangements may continue under specific rules
- Beneficiaries who travel: non-contract suppliers may serve them under specific conditions
Beneficiary impact during CBP rounds
- Beneficiaries in CBAs receiving CBP-category items had to use contract suppliers
- Could be required to switch suppliers when rounds changed
- Generated significant beneficiary access concerns during early implementation
Quality Standards and accreditation (Section 1834(a)(20))
CMS DMEPOS Quality Standards
- Required for all DMEPOS suppliers regardless of CBP status
- Cover business operations, financial management, employee qualifications, beneficiary services, product-specific standards
- Originally established 2007; updated periodically
Accrediting organizations (CMS-approved)
- ACHC (Accreditation Commission for Health Care)
- BOC (Board of Certification/Accreditation)
- CHAP (Community Health Accreditation Program)
- HQAA (Healthcare Quality Association on Accreditation)
- The Joint Commission
- Others as approved by CMS
Surety bond
- $50,000 required for most DMEPOS suppliers
- Higher amounts for high-risk suppliers
- Required for enrollment
DME MAC processing for Georgia
CGS Administrators (Jurisdiction C)
Georgia is in Jurisdiction C, also covering: Alabama, Arkansas, Colorado, Florida, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, Puerto Rico, South Carolina, Tennessee, Texas, U.S. Virgin Islands, Virginia, West Virginia.
CGS Administrators:
- Processes Georgia DMEPOS claims
- Issues redeterminations on appeals
- Applies CMS coverage and documentation guidance
- Maintains LCDs and articles
- Provides supplier education
National Supplier Clearinghouse (NSC)
- DMEPOS supplier enrollment contractor
- CMS-855S enrollment application
- Quality Standards verification
- Site visits
Standard Written Order (SWO) requirements
Required elements
- Beneficiary name
- Order date
- General description of item
- Quantity (if applicable)
- Treating practitioner's name and NPI
- Treating practitioner's signature
Pre-delivery requirement
- For most items, SWO required before delivery
- Certain items have face-to-face encounter requirements
Beneficiary cost-sharing
- Part B deductible
- 20% coinsurance after deductible
- Same under CBP and non-CBP framework
- Medigap may cover coinsurance
- Medicaid for dual eligibles may cover cost-sharing
DMEPOS categories — historical CBP scope
Categories included in various CBP rounds:
- Oxygen and oxygen equipment
- CPAP/RAD (BiPAP)
- Standard power wheelchairs
- Group 3 power wheelchairs (more limited CBP inclusion)
- Manual wheelchairs
- Hospital beds
- Walkers
- Negative pressure wound therapy
- Enteral nutrition
- Diabetic testing supplies (Mail-Order)
- Nebulizers
- Off-the-shelf back braces (Round 2021 implemented)
- Off-the-shelf knee braces (Round 2021 implemented)
Worked examples
Example 1 — Fulton 70 oxygen during Round 2 CBP
Patient: 70-year-old Fulton County resident with COPD, on long-term home oxygen therapy at the time of Round 2 implementation (July 1, 2013). Pre-Round 2: Used a local Atlanta oxygen supplier on fee schedule. At Round 2: Local supplier did not win contract. Beneficiary required to transition to a Round 2 contract supplier. Transition process supervised by CMS with required beneficiary notification. Post-Round 2: Service quality issues required appeal to CGS Administrators and ombudsman intervention. Current (post-January 1, 2024): Oxygen returned to fee schedule. Beneficiary has broader supplier choice subject to enrollment and Quality Standards.
Example 2 — DeKalb 75 power wheelchair under CBP
Patient: 75-year-old DeKalb County resident requiring a Group 2 power mobility device (PMD). Round 2 era: Required to use a Round 2 contract supplier; documentation, LCD compliance, face-to-face encounter, and SWO requirements applied as always. Current: PMDs returned to fee schedule. LCD compliance, F2F, and SWO requirements continue. Choice of suppliers broader.
Example 3 — Cobb 68 CPAP under CBP and post-hiatus
Patient: 68-year-old Cobb County resident with sleep apnea using CPAP. Round 2 era: Contract supplier provided CPAP rental. Cost-sharing 20% Part B coinsurance. Recompete era: SPA updates; potential supplier changes. Current: CPAP returned to fee schedule. Same cost-sharing. Coverage continues under LCD compliance, F2F, SWO requirements.
Example 4 — Worth County 72 non-CBA fee schedule throughout
Patient: 72-year-old Worth County (rural southwest Georgia) resident. CBP impact: Worth County is non-CBA. Beneficiary's DMEPOS items have been on fee schedule throughout all CBP rounds. Current: Continues on fee schedule. Same Part B cost-sharing. Supplier choice unaffected by CBP rounds.
Example 5 — Bibb 80 diabetic supplies under National Mail-Order
Patient: 80-year-old Bibb County resident with type 2 diabetes, receiving diabetic testing supplies by mail. National Mail-Order 2013: Mail-order DTS became subject to National Mail-Order CBP. SPA determined nationally. Current: DTS mail-order pricing continues under the framework established by National Mail-Order CBP. Retail (non-mail-order) pricing handled separately.
Example 6 — Hall 67 off-the-shelf back brace under Round 2021
Patient: 67-year-old Hall County resident, chronic low back pain, prescribed off-the-shelf lumbar support orthosis. Round 2021: Off-the-shelf back braces were one of two product categories implemented under Round 2021. Required use of contract supplier within applicable CBA. Current: Round 2021 contracts continued through their term. After contract expiration, items returned to fee schedule.
Best practices for Georgia DMEPOS suppliers
- Maintain Medicare enrollment with NSC current and accurate
- Maintain accreditation with CMS-approved accrediting organization
- Maintain surety bond at required level
- Comply with Quality Standards continuously
- Train on SWO requirements and documentation
- Coordinate with treating providers for SWO completion
- Maintain LCD compliance in coding, documentation, and clinical criteria
- Track CMS rulemaking on potential future CBP rounds
- Educate beneficiaries on cost-sharing and supplier choice
- Issue ABN appropriately when item is expected to be denied
- Coordinate with DME MAC (CGS Administrators) for guidance
- Maintain accurate billing under correct HCPCS codes
- Manage rental vs purchase appropriately
- Document medical necessity comprehensively
Common issues
- Confusion over CBP vs non-CBP categories during transition periods
- Supplier transitions during CBP rounds were operationally difficult
- Beneficiary access concerns in some CBAs during early rounds
- Service quality concerns with some contract suppliers
- Grandfathering rule complexity for rental items
- Travel beneficiary rules when out of home CBA
- Quality Standards non-compliance leading to denials
- Accreditation lapses disqualifying suppliers
- Surety bond gaps preventing enrollment
- SWO documentation errors causing denials
- Face-to-face encounter documentation gaps for specific items
- LCD compliance gaps
- MA plan procedural differences
- HCPCS coding errors at the supplier level
Frequently asked questions
1. What is the DMEPOS Competitive Bidding Program? A Medicare program established by Section 302 of MMA 2003 (codified at Section 1847 SSA) that uses competitive bidding to set Single Payment Amounts (SPAs) for selected DMEPOS items in selected geographic areas (CBAs).
2. Is the CBP currently active? Most DMEPOS categories returned to fee schedule pricing on January 1, 2024. Round 2021 implemented contracts only for off-the-shelf back and knee braces, which continued through their term. CMS is studying future CBP structure.
3. When did CBP begin? After a halted Round 1 in 2008 (delayed by MIPPA 2008), Round 1 Rebid began January 1, 2011.
4. When did Atlanta become a CBA? The Atlanta-Sandy Springs-Marietta GA MSA became a CBA in Round 2, effective July 1, 2013.
5. What is a Single Payment Amount (SPA)? A single Medicare price for each HCPCS code in a CBA, derived from winning competitive bids.
6. What is the lead item pricing methodology? Adopted in the CY 2021 DMEPOS Final Rule, it designates lead items in each product category with pricing for non-lead items derived from lead item pricing.
7. What is my Medicare cost-sharing? Part B deductible plus 20% coinsurance of Medicare-allowed amount. Same under CBP and fee schedule.
8. Who is the DME MAC for Georgia? CGS Administrators (Jurisdiction C).
9. Do I need a prescription for DME? Yes — a Standard Written Order (SWO) from your physician, NP, PA, or CNS. Many items also require a face-to-face encounter.
10. What is Section 1834(a)(20)? Statutory authority for DMEPOS Quality Standards and accreditation. All Medicare-enrolled DMEPOS suppliers must meet these standards regardless of CBP/non-CBP status.
11. What accrediting organizations approve suppliers? CMS-approved accreditors include ACHC, BOC, CHAP, HQAA, The Joint Commission, and others.
12. What is the surety bond requirement? $50,000 for most DMEPOS suppliers; higher for high-risk suppliers.
13. What is the National Supplier Clearinghouse? The CMS contractor handling DMEPOS supplier enrollment via the CMS-855S application.
14. What about lymphedema compression items? Lymphedema compression items are covered under a new Part B benefit (effective January 1, 2024) under the Lymphedema Treatment Act, separate from CBP. Processed by the DME MAC (CGS Administrators for Georgia).
15. What is grandfathering? A rule allowing certain existing rental arrangements to continue with the same supplier across CBP transitions.
16. Will the CBP resume? The CBP statutory framework is intact. CMS is studying future structure. Future rounds may resume after rulemaking.
17. What happened to suppliers who lost contract bids? Non-contract suppliers generally could not bill Medicare for items in CBP categories in CBAs during active rounds. Some adapted business models; some closed; some served other product categories or non-CBA areas.
18. Did the CBP save Medicare money? CMS has reported substantial savings from CBP rounds — the SPAs were generally well below fee schedule pricing. CBP statutory targets focus on budget neutrality and savings.
19. Were there beneficiary access problems? Early CBP rounds (especially Round 1 in 2008) had documented access concerns. MIPPA 2008 reforms and ongoing oversight addressed many issues. The current hiatus eliminates active CBP access concerns for non-implemented categories.
20. Are non-CBA areas affected by CBP? Generally no during active CBP — non-CBA areas have been on fee schedule. The "rural fee schedule" and "non-rural fee schedule" interact with CBP pricing in specific ways established by statute.
21. What about Medicare Advantage? MA plans must offer coverage at least equivalent to Original Medicare for DMEPOS. Plan-specific networks, prior authorization, and cost-sharing structures may vary. Plan-specific procedures apply.
22. What if my claim is denied? Standard Medicare appeals — redetermination (120 days), QIC reconsideration (180 days), ALJ hearing (60 days), Medicare Appeals Council (60 days), federal court (60 days).
23. How do I find a Medicare-enrolled DMEPOS supplier in Georgia? Medicare.gov supplier directory; referral from your treating provider or hospital social worker.
24. What is the role of LCDs? Local Coverage Determinations issued by the DME MAC (CGS for Georgia) specify clinical coverage criteria, documentation requirements, and ICD-10/CPT/HCPCS coding requirements. LCDs apply across CBP and non-CBP periods.
25. Where can I get help with Medicare DMEPOS in Georgia? GeorgiaCares SHIP (1-866-552-4464), Medicare Rights Center (1-800-333-4114), CGS Administrators (DME MAC), Center for Medicare Advocacy, Atlanta Legal Aid, Georgia Legal Services Program.
Get help with Medicare DMEPOS in Georgia
- Medicare — 1-800-MEDICARE (1-800-633-4227); medicare.gov
- CGS Administrators (DME MAC Jurisdiction C) — cgsmedicare.com
- National Supplier Clearinghouse (NSC) — 1-866-238-9652
- Palmetto GBA (Part A/B MAC for GA) — 1-866-238-9650; palmettogba.com
- GeorgiaCares SHIP — 1-866-552-4464; georgiacares.org
- Medicare Rights Center — 1-800-333-4114; medicarerights.org
- Center for Medicare Advocacy — medicareadvocacy.org
- Acentra Health Georgia QIO — 1-844-455-8708
- Atlanta Legal Aid — 404-377-0701; atlantalegalaid.org
- Georgia Legal Services Program — 1-800-498-9469; glsp.org
- 211 Georgia — dial 211
- Eldercare Locator — 1-800-677-1116; eldercare.acl.gov
- Georgia Department of Public Health — 404-657-2700; dph.georgia.gov
- Social Security Administration — 1-800-772-1213; ssa.gov
- CMS DMEPOS Competitive Bidding Information — dmecompetitivebid.com (CMS-maintained)
- AAHomecare (American Association for Homecare) — aahomecare.org
This guide is provided for educational purposes by Brevy. It does not constitute legal or medical advice. CBP status, product categories, contract suppliers, and pricing are determined by CMS and subject to change. The current hiatus is governed by CMS rulemaking and may evolve. Consult Medicare, CGS Administrators, GeorgiaCares SHIP, or qualified legal counsel for case-specific guidance. Last verified: 2026-05-14.