Medicare Provider Participation Open Enrollment

Brittany Gonzalez
12-10-2025
Blog

The annual Medicare participation open enrollment period began mid-November and ends on December 31. This article will describe the differences between participating and non-participating suppliers and explain how to change your participation status for 2026.


What You Need to Know

Medicare DMEPOS suppliers can choose to be either a participating or non-participating provider. Participating providers agree to accept assignment on all claims for Medicare products and services. They agree to accept the Medicare-allowed amount as payment in full and will collect any unmet deductible and 20% coinsurance from the beneficiary. In comparison, non-participating providers may accept assignment on a claim-by-claim basis. If a non-participating provider does not accept assignment, they can charge more than the Medicare allowable and will collect directly from the patient. In this instance, the supplier is required to file the claim with Medicare on a non-assigned basis on behalf of the patient, and any Medicare reimbursement is sent directly to the patient.

Both participating and non-participating providers are required to follow Medicare coverage policies. An ABN is required for assigned and non-assigned claims when the supplier reasonably expects that Medicare will not pay for the item or service, which is otherwise usually covered by Medicare. If a non-assigned claim is reviewed and payment is denied by Medicare, the supplier will be required to refund the amount collected back to the Medicare beneficiary unless a valid ABN was obtained.

What This Means for You

When considering whether to be a participating or non-participating DMEPOS supplier, you should review current Medicare payment trends and fee schedules. If there are any instances where Medicare reimbursement does not cover your costs, you may want to consider being a non-participating provider so you can choose whether or not to accept Medicare rates on a claim-by-claim basis. In this scenario, you would be able to bill select claims as non-assigned and charge the patient higher rates to help cover your costs, as needed. 

If you do not want to change your current participation status, then there is nothing you need to do during the enrollment period. However, if you do want to change your status, then you need to complete one of the following:

  • Switching from non-participating to participating supplier: Complete the Medicare Participating Physician or Supplier Agreement (CMS-460) and mail a copy to each Medicare Administrative Contractor (MAC) that you’ll send Part B DMEPOS claims to. This form must be postmarked before December 31, 2025.
  • Note: The CMS-460 form expired on November 30, 2025, but it is still under review by the Office of Management and Budget (OMB). A recent MLN Connects Newsletter from CMS announced that the DME MACs will continue to accept the current version of the form until OMB approves the updated form (even if it is dated after November 30).
  • Switching from participating to non-participating supplier: Write to each MAC that you send Part B DMEPOS claims to, telling them that you don’t want to participate, effective January 1, 2026. This written notice must be postmarked before December 31, 2025. 

For more information, review the Annual Medicare Participation Announcement from CMS and Noridian's article on Assignment and Non-Assignment of Benefits.