Back on the Radar
If you've heard rumblings that Medicare's competitive bidding program is coming back, you heard right—and this time it reaches directly into O&P. CMS finalized its 2026 home health and DMEPOS rule in late 2025, officially restarting the Competitive Bidding Program with new contracts targeted for January 1, 2028. Unlike some CMS initiatives that are all noise for years before anything changes, this one has a real timeline and a real list of products—and three of those seven categories are squarely in your world.
CMS has named seven national product categories for the 2028 round, built around what it calls Remote Item Delivery (RID), items that can be shipped to a patient anywhere in the country by mail, rather than requiring a local fitting. Four of those categories are diabetes and urology-related supplies. The other three are ours:
Off-the-shelf (OTS) back braces
OTS knee braces
OTS upper extremity braces
Custom-fabricated and custom-fitted orthoses—anything requiring hands-on trimming, bending, molding, or fitting by a trained professional—stay outside this program entirely. The line CMS draws is around items they think are simple enough to be delivered by mail without a clinician's hands-on involvement.
This isn't the program's first pass at O&P. The 2021 round put OTS back and knee braces through competitive bidding for 2 years before the program paused. What's new for 2028 is the addition of OTS upper extremity braces and a shift to a national, mail-order style contract instead of the old system of regional competitive bidding areas (CBAs). Under this program, a small number of winning bidders will hold contracts to supply OTS back, knee, and upper extremity braces nationally, largely through mail order.
AOPA has publicly pushed back on this, arguing it could delay care and disrupt existing patient relationships, but CMS has indicated it intends to move forward as planned. Practically, that means patients who need a simple OTS knee brace may increasingly be routed to a contract supplier rather than picking one up from you at the time of their visit.
A few details reinforce that this pattern deserves attention:
CMS hasn't finalized the specific L-codes yet for OTS upper extremity braces, meaning the exact scope is still being worked out.
The OTS-designated code list keeps expanding independently. In 2025, CMS added new OTS-parallel codes (L1933 and L1952) for prefabricated ankle-foot orthoses, mirroring existing custom-fitted codes. Every new OTS-designated code becomes a candidate for a future bidding round.
AOPA has flagged "split code set" risk directly to CMS. Many orthotic HCPCS codes exist in pairs — one custom-fitted, one OTS — describing essentially the same device. AOPA warned that pulling only the OTS half of these pairs into competitive bidding could create confusion and delays, since clinicians and patients don't always know in advance which version a patient will need.
A steadily growing OTS code list could suggest O&P's footprint in competitive bidding is more likely to expand than shrink.
"Contract supplier only" is the rule, not a suggestion a non-contract supplier, even one fully enrolled in Medicare, typically couldn't get paid for furnishing a bid item. Losing a bid meant losing that revenue stream entirely for the contract period and CMS is carrying this same structure into the 2028 round for all three OTS brace categories.
What did this Cost? No comprehensive study has put a dollar figure on how much revenue non-contract O&P suppliers lost when Round 2021 shifted billing to a small pool of contract winners. What we do know: CMS's own Competitive Acquisition Ombudsman reported that OTS brace utilization actually declined in competitive bidding areas during the round, with beneficiary inquiries dropping alongside it. CMS has generally attributed lower utilization to the program curbing unnecessary billing rather than patients losing access, but its own reporting doesn't cleanly separate the two explanations for this specific round.
There's a built-in exception worth knowing
CMS has preserved a narrow carve-out: physicians, treating practitioners, and hospitals can furnish certain items—including off-the-shelf orthotics—without being a bid-winning contract supplier, as long as those items go to their own patients as part of a professional service. That's a meaningful detail for practices closely integrated with physician offices, and it's worth confirming with your billing team whether your delivery model qualifies.
Competitive bidding for OTS braces isn't hypothetical anymore, but it's also not a reason to overhaul your practice today. Pull your Medicare claims for L-codes tied to OTS back, knee, and upper extremity braces, and know exactly what volume and revenue is involved. The smart move now is to watch those specific codes determine what the loss of those codes could mean for you (and prepare for that loss). Keep your compliance paperwork current, and stay alert to how the OTS code list evolves — because that list, more than any single rule, is where the next round of change will come from.