Home oxygen therapy: Stakeholders welcome ‘much-needed’ guidance

WASHINGTON – An updated FAQ published by the DME MACs in February, by and large, addresses concerns around the new local coverage determination for home oxygen therapy and serves as a good reference point as HME providers navigate a new era for the benefit, stakeholders say. 

The FAQ, published Feb. 21 and updated Feb. 23, addresses 25 questions related to continued need, the new N modifiers and more. 

“Full stop, it was a much-needed thing,” said Andrea Stark, a Medicare consultant and reimbursement specialist for MiraVista. “It should make it much more easy or attainable to pass auditor reviews and any claim development that comes with that to enforce this policy. It’s so much more aligned with the patient’s medical need and the records are going to more naturally support coverage criteria.” 

While the new oxygen policy, which among other things eliminates the certificate of medical necessity requirement, took effect Jan. 1, there was confusion about the timing of certain requirements. 

For example, new N modifiers, which will replace the KX modifiers, are effective April 1, raising the concern that providers would have to go back through claims for thousands of oxygen patients with dates from Jan. 1 to April 1 to determine which group (N1, N2 or N3) they fall into and add the modifier. 

“For initial claims for oxygen or new oxygen rentals with dates of April service on or after April 1 – that’s when the N modifiers are applied,” said Ronda Buhrmester, senior director of payer relations and reimbursement for VGM & Associates. “So, if the patient was set up on oxygen in January, the N modifiers are not applicable to the claim, but the KX modifier still is.” 

Stakeholders still think, however, there may be room for further revisions to the benefit, like implementing a template of standardized clinical data elements that CMS has already developed, an idea that has been kicking around for several years. 

“We’re still pushing CMS to dust off those CDEs that were developed years ago and use those as an opportunity to really standardize the documentation piece,” said Kim Brummett, senior vice president of regulatory affairs for AAHomecare. “We heard that there’s some conversations about doing a pilot, related maybe not to CDEs but digging into EHRs, which might helpful, but if you are starting at pilot in 2023, it will be quite some time, assuming it is successful, to being rolled out to anything nationwide.” 

• Read about the industry’s concerns about the new LCD and policy article, when they were published in November. 
• Read about why the new national coverage determination for oxygen ushers in a new era for the benefit.