01/12/2026    Paul Kesselman, DPM

CMS Withdraws BOC’s Status as an Accrediting Organization (AO) (Michaela Crawford, DPM)

Dr. Crawford brings up an issue which, while
interesting is insignificant for most physicians
(MD/DO/DPM) who provide DME to their own patients.
Space in this forum only allows me to touch on the
highlights of this issue and there is much more
than what is presented below.

Let me set the record straight so that most if not
all DPMs reading this DO NOT PANIC and understand
they are NOT required to undergo Facility
Accreditation by an accreditation organization
unless they voluntarily want to. Most other DME
providers, including but not limited to
pedorthists, wound care suppliers and your local
neighborhood DME brick and inventory store,
require Facility Accreditation by an accredited
organization.

Let me repeat, physicians are exempt and do not
require facility accreditation when providing DME
as an ancillary service to their OWN patients.
Those last two words are key. If you are filling
prescriptions from other physicians, and you are
not performing a physician evaluation and
management service, which establishes the need for
a DME items, but rather simply filling an order/or
prescription from another provider outside your
practice, then you are not providing DME as an
ancillary service. Under those rare circumstances
you would be required to have your facility
accredited by one of several Accreditation
Organizations (AO).

If on the other hand ,you are the
ordering/prescribing physician and dispensing DME
to your own patients, you can sit back and relax.
There is nothing more you need to do, but become a
bit more educated on this issue, but to repeat, no
other action is required, unless you want to
voluntarily spend thousands of dollars to have an
AO tell you how to conduct your practice. This is
not my opinion but is factual as engraved in the
Medicare Modernization and Improvement Act (MIPPA
2008)

Facility Accreditation is a very separate issue
from DME inspections and revalidation which is a
triennial event. CMS in their recent attempt to
crack down on fraud in the DME world is attempting
to have DME suppliers who require Facility
Accreditation to have that renewed by an AO on an
annual basis. And yes, this, as Dr. Crawford
points out, is a rather expensive process. This
annual review as one can imagine is receiving
significant rebuttal in the DME world, especially
since the BOC Accreditation was revoked by CMS.

The background story here is that one of the
accreditation organizations, specifically BOC, had
their status as an AO revoked because one of their
inspectors was taking bribes to pass DME
facilities or was double dipping and setting up
bogus facilities in their own name and then
providing them with Facility Accreditation so
those organizations could bill Medicare.

As far as which AO Dr. Crawford’s separate entity
should be contracted, Dr. Crawford should refer to
the AO list provided on the CMS website, as within
this forum it would be unethical to endorse one AO
over another.

Lastly, there are Stark and Anti-Incentive Issues
which will need to be navigated if Dr. Crawford,
the physician, refers patients to the separate DME
entity that Dr. Crawford owns or has significant
ownership in. There are also state licensing and
tax issues (both State and County) issues which
Dr. Crawford will need to navigate and an attorney
and accountant both well versed in these subjects
should be consulted.

Pauli Kesselman, DPM, Oceanside, NY

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