CMS reviews second draft of e-templates for oxygen

WASHINGTON - CMS still needs to better clarify which data elements are required to qualify Medicare beneficiaries for home oxygen therapy, says AAHomecare's Kim Brummett.

CMS held a Special Open Door Forum Oct. 26 to review the second draft of its electronic clinical template for home oxygen, including suggested clinical data elements for the order, the face-to-face encounter and the lab test results.

“It's clear that there are some things on there—especially the clinical visit documentation—that are part of the medical record, but aren't required to be on any kind of clinical documentation,” said Brummett, vice president of regulatory affairs.“A lot of feedback will be: What are the requirements on the order? What are the requirements on the values? Not, what would be nice to have?”

CMS released its first draft of the e-templates this past July.

Among the changes in the second draft: “templates” are now “clinical data elements,” which is a good thing, says Brummett.

“They've always just been the data elements that you need,” she said. “A template implies that there's a new form to fill out and that's not necessarily the case.”

Rather, the clinical data elements are a tool that physicians can use to create electronic medical documentation, CMS officials clarified in an email about the forum.

Other changes in the second draft of the e-templates include adding a “value set” of appropriate responses, including “other”; adding a suggested format for the element (e.g. text, numeric); indicating which elements should be considered required to support appropriate documentation; and providing common element names (and codes) across all templates.

The ultimate goal of the e-template is for CMS, HME providers and software vendors to get on the same page, says Brummett, “and hopefully we'll be able to move somewhere with it.”

“CMS developed a template for power mobility devices years and years ago, and that's gone nowhere,” she said. “So we don't want to follow that route, if we can prevent it.”