Oxygen Questions Abound on CERT Call

BALTIMORE — Getting paid for oxygen is no easy task these
days, judging by the questions on a joint CMS-DME MAC CERT call
last week. Members of the CERT (Comprehensive Error Rate Testing)
Education Task Force held a teleconference Feb. 3 to answer
questions on oxygen coverage, testing requirements, CMNs and
documentation — and there was no lack of them.

Representatives from the four DME MACs answered a dozen
questions based on common claims errors, then spent the rest of the
90-minute call responding to live queries with help from Dr. Paul
Hughes, the medical director for Jurisdiction A.

According to officials, there are multiple requirements that
must be documented in order to justify reimbursement. While many
are listed in the local coverage determination, others come from
the national coverage policy, CMS manuals, regulations and
statutes. Oxygen suppliers must be knowledgeable about all of them,
the MAC reps emphasized — and in the event of an audit, “all
applicable reimbursement criteria must be met and sufficient
documentation demonstrating eligibility must be present in the
record.”

Written answers to more than 60 questions submitted before the
call included the following:

Q: What is the responsibility of the provider for
patients who are traveling outside the U.S.?

A: The supplier is not responsible to furnish
oxygen for a patient that travels or resides outside the U.S.

Q: We received a medical review letter and denial
because we don’t have documentation that the patient was seen 30
days prior to initial setup. We have tons of documentation, just
not within 30 days. We had money taken back on this patient. Can we
have them see their doctor and be retested to re-qualify? Would we
start a new 36 months cap rental period or start with the next
billing month that we would have billed?

A: Yes, they can see their doctor and be
retested to re-qualify. A new cap rental period would not begin in
this situation.

Q: If a patient wants to switch suppliers due to poor
service, but 36-rental payments have already been paid, can the
patient switch suppliers?

A: Yes, the beneficiary has the option of
switching suppliers; however, it may be difficult for the
beneficiary to locate a new supplier willing to service them, given
the new supplier will not receive any additional rental payments.
However, if the beneficiary believes their supplier is not
following supplier standards they have the option of reporting the
supplier to 1-800-MEDICARE.

Q: When a patient switches to my company from another,
do I need to get a CMN or just an order confirmation if I have a
copy of the original CMN?

A: A revised CMN must be completed and kept in
your files.

Q: In an audit, is the CMN considered a detailed written
order when section C is filled out properly?

A: Yes, the CMN can be considered a detailed
written order, but the CMN is not a substitute for Medical records
from the treating physician.

Presenters said a written transcript of the call would be
posted on the CMS CERT web page at www.cms.gov/cert
(under the “Providers” tab) two weeks after the call. A replay will
also be available on the DME MAC web sites.