Reimbursement: Document qualifying test result 

Q. What do I need to document in the medical record to meet current oxygen policy requirements?  

A. The current oxygen policy requires the practitioner to order and evaluate the results of a qualifying blood gas study performed at the time of need. I believe this requirement stems from the national coverage determination (NCD) but Medicare confirmed that the practitioner does not necessarily have to document that “I personally reviewed the qualify test result.”  

However, the DME MACs will look for documentation of a qualifying test result in the medical record along with a discussion about the need for oxygen to improve the beneficiary’s condition in the home setting. For example, if the qualifying test result is documented in the vital of the practitioner’s progress note and the practitioner mentioned the need for home oxygen therapy, I believe this will comply with the LCD requirement.  

Alternatively, the practitioner can co-sign or initial the qualifying test result as evidence of his or her evaluation. The DME MACs have confirmed that this would be acceptable. For example, an overnight pulse oximetry was done by an independent diagnostic and testing facility (IDTF) and the qualifying result faxed to the doctor’s office. Instead of memorializing the result in the progress note, the practitioner can sign or initial the test result and incorporate it into the patient’s chart.   

In late 2023, Medicare began auditing oxygen under the Targeted Prove and Educate (TPE) program. Oxygen suppliers, especially medium to larger providers, should keep their eyes peeled for TPE notification letters.  

For beneficiaries residing in Jurisdiction B and C, CGS has created a great program called CGS Connects. CGS Connect provides a unique concierge-level service professional review and evaluation of pre-claim documentation before suppliers submit an initial claim to Medicare. They are currently accepting requests for oxygen (E1390) only for the beneficiary’s initial claim. This is a great program for suppliers to utilize if they are unsure the available documentation meets Medicare guidelines.  

Noel Neil JM, CDME, is vice president of corporate compliance and auditing for ACU-Serve. Reach him at 561.778.4454 or nneil@acuservecorp.com.