For DME suppliers, your CHAP accreditation isn’t just a certificate; it’s the backbone of your Medicare DMEPOS enrollment, payer credentialing, and day-to-day operational compliance. When your organization changes its physical location, adds a warehouse, opens a branch, or expands into new DME product categories, those changes can trigger CHAP review requirements, Medicare enrollment updates (CMS-855S/PECOS), state licensing updates, and even commercial payer recredentialing.

This step-by-step guide explains exactly what to do so you stay compliant, avoid site visit failures, and protect your billing privileges.

Why These Changes Matter: CHAP, Medicare, and Payers Must Match

A common compliance risk for DME suppliers is mismatched information across:

• CHAP accreditation records
• CMS-855S / PECOS enrollment information
• State DME/HME licensing

Commercial payer credentialing profiles

Even if you are operating appropriately, inconsistencies can lead to:

• Off-cycle CHAP surveys
• Failed NSC (National Supplier Clearinghouse) site visits
• Payment holds, deactivation, or revocation (in serious cases)
• Delays in commercial payer participation

Part 1: Impact of a DME Supplier Location Change on CHAP Accreditation

What counts as a “location change” for a DME supplier?

CHAP generally views these as material changes:

• Moving your main DME service location
• Changing your practice/service address on file
• Adding a new branch or satellite location
• Adding or changing a warehouse/inventory storage site
• Using a temporary storage or shared space tied to operations

Key point

CHAP accreditation is site- and operations-sensitive. If you store inventory, serve patients, coordinate delivery, or manage PHI at a site, CHAP may need to review it.

Step-by-Step: What to do when your DME supplier address changes

Step 1 — Classify the change (Day 0)

Decide which category applies:

• Move (same business, new address)
• Add a new branch (new operational site)
• Add a warehouse (inventory storage location)
• Admin-only office (case-by-case)

Best practice: If it impacts inventory, delivery workflow, patient services, or PHI—treat it as material.

Step 2 — Notify CHAP (typically within 10–30 days)

Notify CHAP in writing and include:

• Effective date of change
• Old address and new address
• Whether patients are served at the site
• Whether inventory is stored there

Any changes to staffing, workflow, or scope of services

Common CHAP requests (prepare these early):

• Updated floor plan showing inventory areas
• Safety measures (secure storage, access control)
• Updated operational policies/SOPs tied to the new site

HIPAA safeguards (PHI storage, workstation security)

Possible outcomes:

• Desk review only
• Focused virtual survey
• Onsite focused survey (especially if operations or storage changed)

Step 3 — Update Medicare enrollment (CMS-855S / PECOS) within 30 days

For DME suppliers, location updates must be aligned in:

• CMS-855S enrollment record
• PECOS profile
• Any listed warehouse/storage locations (if applicable)

Important: Medicare site visits (NSC) are address-driven. If CHAP says one thing and CMS shows another, you’re exposed to audit risk.

Step 4 — Update state DME/HME licensing

Many states require:

• Address updates on the license
• Branch permits for additional locations
• Potential inspections or additional documentation

Best practice: Don’t assume “address only” is simple—verify state rules before operating fully at the new site.

Step 5 — Notify commercial payers and Medicaid (as applicable)

Update credentialing and enrollment profiles with:

• Physical address
• Mailing/billing addresses (if changed)
• Service location and delivery footprint
• Revalidation requirements (if triggered)

Step 6 — Perform internal readiness validation

• Before your first CHAP/NSC visit at the new site:
• Ensure signage, access, and secure storage are ready
• Inventory organization is clean vs. used/returned segregation (if applicable)
• Documentation is retrievable onsite (policies, QA logs, training records)

Part 2: Impact of Adding New DME Supplies or Product Categories on CHAP Accreditation

Does adding new DME supplies affect CHAP accreditation?

Sometimes. The key factor is whether you’re making a minor expansion within your current scope—or adding higher-risk categories that require new policies, training, and oversight.

Examples that are typically lower impact (still disclose)

• Adding SKUs within the same category (e.g., additional CPAP accessories)
• Adding new vendors for an already-approved supply line
• Examples that often trigger CHAP review
• Adding a new product category
• Expanding into high-risk supplies/equipment (example: oxygen-related workflows)
• Adding patient-specific or custom-fit items requiring documented competencies
• Expanding into complex rehab or specialty equipment

Step-by-Step: What to do when expanding DME supplies

Step 1 — Define what you’re adding

Document:

• Product category and typical HCPCS range (internally)
• Whether it requires setup, education, or clinical oversight
• Delivery requirements and patient training workflow

Step 2 — Update CHAP scope and documentation

Notify CHAP and update:

• Scope of services (internal + accreditation profile)
• Policies and procedures (delivery, setup, cleaning/maintenance, patient education)
• QA/incident processes (complaints, adverse events, recalls)

Step 3 — Staff training and competency documentation

Surveyors and payers want proof of:

• Training completion
• Competency validation (checklists)
• Roles and responsibilities for setup, delivery, troubleshooting, patient education

Step 4 — Inventory, storage, and tracking controls

Implement or update:

• Secure storage and environmental controls (as needed)
• Lot/serial tracking processes (best practice)
• Recall management and vendor documentation retention
• Segregation processes (new vs returned/used equipment, when applicable)

Step 5 — Medicare and payer readiness

Confirm:

• CMS-855S / PECOS updates if needed
• Patient documentation workflows (medical necessity, coverage criteria)
• ABN workflow (when applicable)
• Commercial payer enrollment impacts (some require scope disclosure)

DME Supplier Compliance Checklist (CHAP + Credentialing Ready)

A. Location Change Checklist

• CHAP notified (written notice submitted)
• Floor plan and site documentation updated
• Policies updated (delivery, safety, HIPAA/PHI safeguards)
• CMS-855S/PECOS updated within the required timeframe
• State DME/HME licensing updated
• Commercial payer and Medicaid updates completed
• Internal mock audit/site visit readiness completed

B. Adding Supplies / Expanding Scope Checklist

• CHAP scope disclosure completed
• New policies and procedures implemented
• Staff training and competency documentation completed
• Vendor qualification and IFU documentation retained
• Storage, tracking, and recall workflow ready
• Medicare/payer billing requirements confirmed

Common High-Risk Mistakes DME Suppliers Should Avoid

• Operating from a new address before aligning CHAP + CMS + state licensing
• Not disclosing a warehouse/inventory storage location
• Adding higher-risk product categories without training documentation
• Failing NSC site visits due to address mismatch or incomplete operational readiness
• Missing change reporting timelines (CHAP/CMS/state)

Best-Practice Tip: Build a “Change Control” SOP for DME Suppliers

DME suppliers grow fast—new locations, new services, new payers. A simple internal change control process helps prevent compliance gaps:

Identify Change → Assess Risk → Notify CHAP → Update CMS/State → Update Payers → Train Staff → Validate Readiness

Conclusion

If you’re a DME supplier planning to move locations, add a warehouse, open a branch, or expand your DME supplies, treat it as a coordinated compliance project. CHAP accreditation, Medicare enrollment (CMS-855S/PECOS), state licensing, and payer credentialing must stay aligned to protect your billing privileges and avoid survey or site visit issues. Contact TriumpHealth today to learn how our experts manage every step, from initial application to revalidation, to eliminate errors, shorten timelines, and ensure approval. For more details, you can schedule a consultation, or call us at (888) 747-3836 x0, or email us at [email protected].