Is PAP replenishment next? Suppliers should read writing on wall Round 2028 could be the blueprint for CMS’s next expansion of nationwide RID
By Scott Owsiak
Updated 3:05 PM CDT, Tue October 27, 2026
The Centers for Medicare & Medicaid Services’ (CMS’s) plan to revive the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies Competitive Bidding Program (DMEPOS CBP) in 2028 should prompt suppliers to look beyond the seven product categories included in the upcoming round. The more important question may be: What comes next?The history of competitive bidding offers a clue. The concept began as a limited demonstration in Polk County, Fla., and San Antonio. After CMS tested the model, it expanded competitive bidding to major metropolitan areas, added product categories and eventually used bidding results to influence reimbursement throughout the country.
Round 2028 may represent a similar starting point for CMS’s new Remote Item Delivery (RID) model.
CMS plans to establish one nationwide competitive bidding area for seven categories: continuous glucose monitors (CGMs) and insulin pumps, urological supplies, ostomy supplies, hydrophilic urinary catheters, and off-the-shelf back, knee and upper-extremity braces. Each of these categories is commonly supplied from locations that may be hundreds of miles from the beneficiary.
Although CMS calls this a phased implementation rather than a pilot, the practical effect may be much the same. The agency can test whether a relatively small group of national contract suppliers can serve beneficiaries effectively, produce savings and maintain access across an entire nationwide service area.
If CMS views Round 2028 as successful, suppliers should expect the agency to consider additional products that fit the same remote-delivery profile. Positive airway pressure (PAP) replacement supplies could be near the top of that list.
Masks, cushions, tubing, filters and headgear are standardized, frequently replenished products that can be shipped directly to beneficiaries. Once a patient has been set up on therapy and the appropriate interface has been established, much of the ongoing replenishment process can be managed remotely. From CMS’s perspective, that makes PAP supplies look more like CGMs and ostomy and urological supplies than service-intensive equipment requiring repeated local
delivery.
The spending and program integrity implications also make PAP replenishment an attractive target. The U.S. Department of Health and Human Services Office of Inspector General (OIG) reported that Medicare paid about $945.8 million for replacement PAP supplies in 2017 and 2018. The OIG has also scrutinized whether replacement claims meet Medicare’s medical necessity, documentation and refill requirements. CMS’s 2025 improper payment data projected more than $122 million in improper continuous positive airway pressure (CPAP) payments, with a 10.6% improper payment rate.
Competitive bidding would offer CMS a way to address price, supplier participation and program integrity at the same time.
This does not mean CMS has announced PAP supplies for a future round. It has not. CMS also says RID model is expected to focus on categories normally furnished from remote supplier locations. That limitation may protect products requiring substantial local setup, maintenance or clinical support, but it does little to exclude routine PAP replenishment.
Suppliers should therefore treat Round 2028 as more than a competition involving seven isolated categories. It may establish the operational blueprint for future nationwide competitions involving replenishment supplies.
The lesson from the original competitive bidding demonstrations is straightforward: CMS often begins with a manageable scope, evaluates the results and expands from there. If nationwide remote delivery works for CGMs, ostomy products, urological supplies and braces, PAP replenishment will be an obvious candidate for a subsequent round.
The writing may already be on the wall. PAP suppliers should use the period before 2028 to strengthen refill documentation, demonstrate the value of patient engagement and clinical support, improve shipping and nationwide service capabilities, and understand how their businesses would perform under a competitively bid reimbursement model.
Waiting until CMS formally names the next categories may mean waiting too long.
Scott Owsiak, MHA, RRT, is system director for All Saints Home Medical Equipment in Tulsa, Okla.
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