Respiratory Care Providers Unite to Urge CMS to Use Existing Template for Supplemental Oxygen 

October 12, 2023 

Leading Respiratory Care Groups Champion Medicare Documentation Reforms to Standardize a Template, but Caution CMS that Focusing on the Electronic Interface Instead of the Clinical Data Elements Risk Complicating What Should Be a Straightforward Process 

Washington, D.C. – The Council for Quality Respiratory Care (CQRC) – a coalition of the nation’s leading home respiratory therapy providers and manufacturing companies – recently joined 5 other respiratory care groups in sending a letter to the Centers for Medicare & Medicaid Services (CMS), asking the agency to require Medicare contractors to use a standard clinical data element template for supplemental oxygen in order to ensure beneficiaries, prescribers, and suppliers will not be overburdened with audits. While the groups appreciate the development of an eClinical oxygen template pilot program by CMS, they expressed concern that the pilot program’s current focus on an electronic interface will not be useful until CMS adopts standardized clinical data elements. 

In a letter written to the Centers for Medicare & Medicaid Services and sent by CQRC, AAHomecare, American Association for Respiratory Care, American Thoracic Society, American College of Chest Physicians (CHEST), and The VGM Group, the stakeholders urged CMS to delay adoption of a streamlined and transparent template while electronic data submission systems are being developed. 

The current process for prescribers ordering supplemental oxygen for their Medicare patients recognizes only a physician’s medical record notes as the source for establishing if a patient needs a device. This approach poses a significant administrative burden on healthcare providers who write their notes to support the care of their patients, not to meet the desired wording of Medicare contractors for the auditing process. Without standard clinical data elements, the auditing process can be needlessly slow and resource intensive—when a streamlined alternative would be preferable to all stakeholders. Therefore, the groups propose CMS adopt a far more simplified and effective process through a standard template that can be delivered through electronic means once the standard clinical data elements are agreed upon. 

“While we were hopeful that the pilot would be the next step in achieving the goal of replacing medical record review with a set of standardized clinical data elements that would clearly 

indicate what information prescribers need to provide when ordering supplemental oxygen for their patients, it appears that the pilot is focusing on the electronic interface instead of the clinical data elements in the template and complicating what should be a straight-forward process,” the letter reads. 

The focus on clinical data elements within the supplemental oxygen template is crucial for ensuring that medical necessity is appropriately assessed. Relying solely on prescribers’ notes has proven to be problematic, and this challenge must be addressed to protect the interests of beneficiaries and all stakeholders involved in the Medicare program. 

While CMS works to streamline the supplemental oxygen prescription process, the groups urged CMS to “use the existing CMS template (modified consistent with the community’s recommendations) so that as audits resume, beneficiaries, prescribers, and suppliers will not be overburdened with audits.” 

CQRC is fully committed to supporting these efforts to protect beneficiaries, prescribers, suppliers, and the integrity of the Medicare program. As a coalition of the nation’s leading home oxygen therapy providers and manufacturing companies, CQRC is eager to work collaboratively with CMS and other stakeholders to ensure the successful implementation of the recommended changes. 

To read the stakeholder letter to CMS, CLICK HERE. 

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