Billing/Reimbursement

New Oxygen Policy Synchronizes RULs

Industry consultant Andrea Stark of MiraVista LLC offers a clear explanation of how CMS' new reasonable useful lifetime (RUL) policy for stationary and portable oxygen equipment affects HME suppliers.

The following release from MiraVista LLC includes a clear explanation from industry consultant Andrea Stark on how CMS' new reasonable useful lifetime (RUL) policy for stationary and portable oxygen equipment affects HME suppliers. Announced in CR 7213, the new policy took effect May 8, 2011. For additional information, contact Stark at customerservice@miravistallc.com.

COLUMBIA, S.C. — On May 8, 2011, a new oxygen policy went into effect that synchronizes the reasonable useful lifetimes (RUL) of stationary and portable oxygen equipment. In cases where a patient has both stationary and portable equipment, the RUL of the stationary unit will now serve as the RUL for both pieces of equipment, regardless of when the portable was prescribed.

The most common reason for asynchronous RULs between stationary and portables is that a patient initially qualified nocturnally. Patients who initially qualify for oxygen therapy during sleep only qualify for stationary equipment and must secure a separate test, while they are awake, to qualify for portability.

DME consultant and reimbursement expert Andrea Stark expects the change will be positive for most suppliers.

"It's important to note that the new policy is just synchronizing the reasonable useful lifetime at the 60-month mark. It is not directly affecting the capped rental mark of 36 rental payments," Stark said. "The majority of suppliers will still receive their full 36-months of rental for both pieces of equipment, with the added bonus of starting new capped rentals for their portable units earlier."

According to Stark, portable equipment is generally prescribed along with, or shortly after, a stationary concentrator. So for the majority of suppliers, the new rule means less time servicing portable equipment and less time providing contents they can't bill for separately.

For example, if a patient is prescribed a portable system six months after a concentrator, the supplier may bill for the following once the concentrator caps at 36 months:

  • Six additional months of simultaneous billing for the remaining portable rentals and portable contents to reach the portable's 36-month cap (billing for portable contents may begin only after the stationary unit caps).