AAHomecare Asks for Clarification on O2 Cap in DRA

Alexandria, Va.

The American Association for Homecare is asking CMS for more details on the oxygen and DME rental cap provisions in the Deficit Reduction Act.

In an April 20 letter addressed to Herb Kuhn, director of CMS’ Center for Medicare Management, the association said it is concerned about a number of issues involving implementation of the DRA — signed into law on Feb. 8 — which will cap Medicare rental of home oxygen equipment at 36 months and transfer title to the beneficiary, as well as eliminate the cap rental option for DME.

“AAHomecare understands that these new payment methodologies do not take effect immediately. However, their impact on our members’ operations is immediate because they must begin to structure their operations to respond to the changes,” the letter said. “Moreover, providers must plan now for their implementation in order to ensure a smooth transition for Medicare beneficiaries.”

The letter lists 33 questions addressing medical necessity and documentation, reimbursement, service and maintenance and other issues. Questions include:

• How will CMS define “oxygen” after the 36-month period of continuous use ends?
• Will CMS issue temporary HCPCS codes to identify the service, maintenance and repairs for oxygen equipment, or will providers have to apply for the codes?
• For beneficiary-owned equipment that requires servicing, will Medicare pay pick up and delivery charges?
• When a beneficiary owns his or her oxygen equipment, will Medicare pay for new equipment on the basis of a change in condition?