OXYGEN TEMPLATE: CQRC ENLISTS CONGRESS 

HME News Staff

Updated 10:20 AM CDT, Tue September 12, 2023

WASHINGTON – Fourteen members of the U.S. House of Representatives have sent a letter to CMS urging the agency to clarify Medicare documentation requirements for supplemental oxygen and adopt a standardized template for documenting patient need, according to the Council for Quality Respiratory Care. 

“We write to request that auditors accept the standard written order (SWO) as the only necessary documentation to establish medical necessity when auditing claims of patients who received home oxygen, sleep therapy, or non-invasive ventilation equipment,” the letter reads.    

The bi-partisan group, led by Reps. Terry Sewell, D-Ala., and Adiran Smith, R-Neb., sent the letter to CMS Administrator Chiquita Brooks-LaSure. 

The CQRC says since CMS has not acted on its request, it’s time for Congress to let the agency know that it should adopt the template. 

“If CMS allows contractors to rely only upon physicians’ medical record notes, a vast majority of patient claims will be denied, creating access issues for beneficiaries,” the letter states. “CMS already created the oxygen clinical data element templates, which are more practical in assessing coverage needs. We, therefore, urge CMS to require contractors to use these templates, along with the standard written order, in lieu of medical record notes when determining medical necessity.” 

Industry stakeholders hope an upcoming pilot project by CMS will test the use of a template for oxygen. 

Earlier this year, the DME MACs did publish an FAQ to provide guidance on the new local coverage determination (LCD) for oxygen. 

Council for Quality Respiratory Care (CQRC), Oxygen, Template