CMS upends oxygen CMN

WASHINGTON - CMS has changed the guidelines for reporting a patient's oxygen flow rate on a CMN, a move that will have two serious implications for providers, particularly those servicing the critically ill, says Andrea Stark.

First, through new modifiers laid out in a Feb. 15 joint DME MAC publication, CMS has instructed that for patients whose oxygen use differs between day and night, the average flow rate, not the highest flow rate, must be reported on question 5 of the CMN.

“They say this is going to simplify the process, but it makes things ten times more complicated,” said Stark, a reimbursement consultant for MiraVista LLC.

CMS has added three new modifiers, set to go into effect April 1: QA (prescribed amounts of stationary oxygen for daytime use while at rest and nighttime use differ and the average of the two amounts is less than 1 liter per minute); QB (prescribed amounts of stationary oxygen for daytime use while at rest and nighttime use differ and the average of the two amounts exceeds 4 liters per minute and portable oxygen is prescribed); and QR (prescribed amounts of stationary oxygen for daytime use while at rest and nighttime use differ and the average of the two amounts is greater than 4 liters per minute).

Second, by modifying existing modifiers QE, QF and QG, CMS has instructed that patients must now need more than 4 liters of oxygen per minute “at rest,” not at exertion, to qualify for a high-volume adjustment that increases reimbursement from $70.74 per month to about $106 per month.

“This will exclude patients who previously qualified for high-volume adjustments,” Stark said.

The reimbursement difference for a patient considered standard volume and high volume is about $20 to $30, a change that may be hardly worth the savings when you consider the upheaval to the documentation process and the possible threats to patients, Stark says.

“With the existing reimbursement cuts, this is just one more blow,” she said. “These high-liter-flow patients are the most expensive patients to take care of, and providers aren't going to be paid nearly enough.”