Industry on home oxygen: We need ‘objective standards for review’

WASHINGTON – AAHomecare, VGM & Associates, the Council for Quality Respiratory Care and 11 other organizations are asking CMS to eliminate the medical record review for home oxygen therapy and to accept the clinician prescription/standard written order as the required documentation for establishing medical necessity. 

These changes would protect against fraud and abuse, reduce the burden on clinicians and suppliers, and protect access for Medicare beneficiaries, the groups say in an Oct. 4 a letter sent to CMS Administrator Chiquita Brooks-LaSure. 

“The goal of the medical necessity review is to protect the federal government and beneficiaries from fraud,” the letter states. “Yet, this well-intentioned program has morphed into an assessment of clinician charting that does not identify fraud or abuse. Without clear, objective standards for review, it will become difficult for suppliers to continue filling clinician prescriptions for beneficiaries. It is time to fix this broken system and make sure that beneficiaries maintain access to these important home oxygen therapies.” 

The groups are making the request in connection with CMS’s recent decision to drop the CMN requirement for home oxygen, as well as to expand access to the therapy for acute conditions. 

The groups say they also support an alternate approach to require clinicians to complete the existing supplemental home oxygen templates, which, when submitted with a prescription, would constitute the sole documentation to establish medical need and be sufficient for medical necessity review. 

Currently, under the public health emergency, CMS has not required clinician medical record notes to document medical necessity. Instead, medical necessity documentation has been based on the clinician’s prescription and the SWO.