Reminder - Oxygen Qualification Tests and Documentation - Revised - JD DME

Joint DME MAC Publication
Published December 22, 2022

With advances in electronic health records and billing software, healthcare providers and durable medical equipment (DME) suppliers often have interconnected systems for the transmission of medical records and other documentation such as orders. Suppliers are reminded that the Centers for Medicare and Medicaid Services National Coverage Determination (NCD) for Home Use of Oxygen (Internet-Only Manual 100-03, Chapter 1, Part 4, Section 240.2) and the DME MAC Local Coverage Determination (LCD) and LCD-related Policy Article (PA) on oxygen equipment both prohibit supplier involvement in the qualifying test process for home oxygen therapy. As noted in the DME MAC Oxygen and Oxygen Equipment LCD:

The qualifying blood gas study must be one that complies with the Fiscal Intermediary, Local Carrier, or A/B Medicare Administrative Contractor (MAC) policy on the standards for conducting the test and is covered under Medicare Part A or Part B. This includes a requirement that the test be performed by a provider who is qualified to bill Medicare for the test – i.e., a Part A provider, a laboratory, an Independent Diagnostic Testing Facility (IDTF), or a treating practitioner. A supplier is not considered a qualified provider or a qualified laboratory for purposes of this policy. Blood gas studies performed by a supplier are not acceptable. In addition, the qualifying blood gas study may not be paid for by any supplier. These prohibitions do not extend to blood gas studies performed by a hospital certified to do such tests. [Emphasis Added]

In addition to the rules noted above, suppliers are also reminded that the ordering of any oxygen qualification test (i.e., arterial blood gas or pulse oximetry) may only be done by the treating practitioner, with the results sent directly to the treating practitioner. The common practice where a DMEPOS supplier arranges or otherwise facilitates testing and subsequently has the practitioner "order" the already conducted test does not result in a qualified test for the purpose of Medicare oxygen reimbursement. Refer to the DME MAC Oxygen and Oxygen Equipment LCD and LCD-related PA for additional coverage, coding and documentation requirements.

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