MACs Issue Travel Oxygen Article

ATLANTA — On Thursday, the DME MACs issued an article on
travel oxygen related to short-term travel (days or weeks) and
temporary relocation, such as for snowbirds.

Under a new payment policy for oxygen effective Jan. 1, the
article notes, if a beneficiary travels or relocates outside the
provider’s service area, “then for the remainder of the rental
month for which it billed, the home supplier is required to provide
the oxygen itself or arrange for a temporary supplier (non-billing)
to provide the oxygen.”

“Historically, providers weren’t responsible for providing
travel oxygen, and the patient had to make arrangements for that or
pay on their own,” according to Lisa Smith, a health care attorney
with Brown &
Fortunato, Amarillo, Texas. “This is definitely changing that
picture.

“If you have provided oxygen for a patient during a month
Medicare pays for it, then you’re going to be required to provide
travel oxygen as well.”

Additional requirements for home providers:

• For subsequent rental months that the beneficiary is outside
  the service area, the home supplier is encouraged to either provide
  or arrange for the oxygen itself or assist the beneficiary in
  finding a temporary supplier (billing) in the new location.
• If the home supplier provides oxygen to the patient for use
  out-of-area or arranges for a temporary supplier (non-billing) to
  provide the oxygen, the home supplier bills for whatever system the
  patient is using on the anniversary date/billing date. The supplier
  may provide the patient with different oxygen equipment (e.g.,
  portable concentrator) for travel, if there is an order from the
  physician.
• The home supplier may not bill for or be reimbursed by Medicare
  if it is not providing oxygen or has not arranged for a temporary
  supplier (non-billing) to provide the oxygen on the anniversary
  billing date.

Requirements for temporary providers:

• If it is during a month in which the home supplier has not
  billed Medicare, claims from the temporary supplier (billing) would
  be paid, if all coverage criteria and payment rules are met.
• If it is during a month in which the home supplier has billed
  Medicare and it is not provided under an arrangement with the home
  supplier, then the claim from the temporary supplier (billing) will
  be denied as not medically necessary, if it bills Medicare.
• If the beneficiary returns home before the end of a rental
  month for which the temporary supplier (billing) has billed, it
  must provide oxygen itself for the entirety of that month or make
  arrangements with the home supplier to provide the oxygen.
• The temporary supplier (billing) must provide a copy of a valid
  CMN, an order (if the order information was not included on the
  CMN), a report of the qualifying blood gas study, and documentation
  of any required physician visit, if requested.

The article also gives instructions for providing oxygen in
months 37 through 60:

• The supplier providing oxygen to the patient during the 36th
  month is required to provide oxygen to the patient either directly
  or under arrangements with a temporary supplier (non-billing) for
  beneficiary use out-of-area.
• The home supplier could provide the patient with different
  oxygen equipment (e.g., portable concentrator) for travel, if there
  is an order from the physician.
• The supplier would not submit a claim for that equipment
  (because it is required to continue to provide equipment after the
  36 month cap).
• If the beneficiary had a gaseous or liquid system during the
  36th month and the supplier was providing contents to the patient
  during months 37-60, it may only bill and will only be reimbursed
  for contents if the patient was using contents at some time during
  the billed month. It may not bill for contents if, for example, the
  beneficiary was using a portable concentrator during the entire
  month.

Smith, who recently authored a Q&A series on
the 36-month oxygen cap and post-cap payment rules for
HomeCare Monday, said she is asking CMS for clarification
on billing for travel oxygen and other points in the MACs’ new
instruction.

But one frustrated oxygen provider said the gist of the article
is all too familiar: “It’s one more thing that doesn’t fix
anything,” said Bill Baker, RRT, of RxO2 in Tucson, Ariz. “It makes
it worse. Nobody is going to touch a traveler. It’s too much
trouble.”

Read the full travel oxygen article on the Jurisdiction C
(Cigna) Web site.