While everyone focused on wheelchairs and “Operation Wheeler Dealer” in September, the Centers for Medicare and Medicaid Services nonchalantly slipped the long-awaited oxygen policy into its latest round of updates.
The final policy included a few big changes and several smaller nuances that raise more questions than answers. The changes and their impact on your operations are detailed below:
For patients who qualify for oxygen based only on a sleep study, the test results must show a qualifying test value present for at least five minutes. This does not mean that it has to be five continuous minutes. Rather, the patient must have a qualifying test value for a total of five minutes during a night's sleep. Currently no minimum length of sleep is specified for oxygen.
Impact: The operational impact should not result in much change to the number of qualified patients.
Retesting and recertification for oxygen is required at three months of use. The proposed draft policy changes the recertification of Group I patients from the current 12 months to three months and requires retesting prior to recertification. Medicare says that, due to “technical considerations” relating to implementation,” this has not yet been included in the policy revisions. Some in the industry are breathing a short sigh of relief.
“Perhaps postponing this requirement is caused in part by the insufficient number of qualified [independent] testing facilities available due to the low reimbursement rates,” speculates Kim Brummett, vice president of contracting and reimbursement for Advanced Home Care in Greensboro, N.C.
“Physicians are not interested in purchasing or renting equipment for which they will not be adequately reimbursed,” Brummett adds.
Many companies require a complete overnight respiratory assessment by an IDTF to get the patient tested. Even then, the companies available to conduct such studies are few and far between. The delay in getting qualifying tests can be weeks.
Impact: While waiting for this change, find an IDTF to handle your cases. In addition, educate your physician community, which perhaps can shoulder some of the burden by testing in their offices, even if it is financially limiting.
A few of the many nuances addressed in the policy include:
Second chance-retroactive billing is okay. If a patient is not reevaluated within 90 days prior to recertification, payment will be made retroactively to the scheduled recertification date. This is contingent upon the patient seeing the doctor. In addition, when they see the doctor, the blood gas results must qualify the patient.
Impact: If you miss a date, get the patient tested as quickly as possible so that you can back bill to the original recertification date. For example, if the patient was to be recertified on Oct. 1 and it is now Nov. 15, as long as the patient qualifies for oxygen (with the proper test results) when they do see the doctor, you may restart the billing cycle on Oct. 1. I recommend that you document this in the narrative field of your electronic claim to ensure that Medicare is aware of the discrepancy in the testing and billing dates.
For portable oxygen systems, the supplier must provide whatever quantity of oxygen the patient uses. While we always knew this to be true, it is finally printed in black and white. This means that you cannot ration each patient's allotment of portable oxygen tanks.
Impact: Always encourage patients to come in and pick up portable tanks, especially if the patients are ambulatory.
Final Analysis
The current changes should not force providers out of business, although a three-month retesting requirement could cause serious delays in patient access. Without proper access to testing, some patients may ultimately go without the oxygen. In the interim, secure as many testing options as possible while awaiting Medicare clarification on the recertification issues.
Miriam Lieber is president of Lieber Consulting, specializing in operations management and reimbursement for the HME industry. She can be reached by e-mail at mllieber@pacbell.net or by phone at 818/789-0670.
