The following questions and answers (Q&As) are cumulative from the DMEPOS Ask the Contractor Meeting (ACM) held on August 19, 2026. Some questions have been edited for clarity, and answers may have been expanded to provide additional explanation. Similar questions were combined to eliminate redundancy. If a question was specific to one supplier's claim or situation, Noridian addressed it directly with the supplier outside of the ACM.

Questions Received Prior to ACM Meeting

Q1. Regarding sleep studies, when a patient is switching suppliers and the original diagnostic sleep study cannot be obtained, is the patient required to undergo a new sleep study if Medicare did not pay for the original Continuous Positive Airway Pressure (CPAP) machine?
A1. If the original diagnostic sleep study cannot be obtained, a new qualifying sleep study and supporting documentation are required to meet Medicare coverage requirements, regardless of whether Medicare paid for the original CPAP device or not.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Positive Airway Pressure (PAP) Devices

Q2. For the Respiratory Assist Device (RAD) Local Coverage Determination (LCD), when the diagnosis is Central Sleep Apnea (CSA), does a home sleep test (HST) documenting CSA, along with a titration study performed on the prescribed device, satisfy the coverage requirements? Or is a facility-based diagnostic polysomnogram (PSG) documenting CSA required, followed by a titration study on the prescribed device? In other words, for CSA, can an HST be used to establish the diagnosis, or is a facility-based diagnostic PSG required?
A2. For CSA under the RAD LCD L33800, Medicare requires a facility-based diagnostic PSG. A HST cannot be used to establish the diagnosis of CSA for RAD coverage.

Resource: Noridian Medicare website > Browse by Topic > Respiratory Assist Devices

Q3. Are specific manufacturers' products required to be listed on the Pricing, Data Analysis and Coding (PDAC) contractor's Product Classification List (PCL) under a given HCPCS code to be billed to Medicare? Some of our manufacturers have stated that their products do not need to be listed on the PDAC Product Classification List to be billable. Can you clarify whether PDAC listing is required, and if so, under what circumstances?
A3. Not all products are required to be listed on the PDAC PCL to be billable. However, for HCPCS codes that require PDAC coding verification review, the product must be listed on the PDAC PCL. If it is not listed, the claim will be denied.

Resource: Items Requiring Coding Verification Reviews on PDAC website

Q4. Is it acceptable to include checkboxes in Box E, "Reason Medicare May Not Pay," allowing the beneficiary to select the single most appropriate reason applicable to the Advance Beneficiary Notice of Noncoverage (ABN)?
A4. As a reminder, a new ABN form was issued March 13, 2026; all new issued ABNs must use the updated form to be valid. Although the updated form no longer identifies this section as "Box E," the "Reason Medicare May Not Pay" section remains. Enter only the applicable reason(s) Medicare is expected to deny coverage. If multiple denial reasons apply, all applicable reasons may be listed. Adding reasons that do not apply may invalidate the ABN. CMS permits only limited customization of the ABN, adding checkboxes to the ABN is not allowed if they alter the content, beneficiary options, or required format of the CMS approved form.

Resource: Noridian Medicare website > Browse by Topic > Advance Beneficiary Notice of Noncoverage (ABN)

Q5. Would this qualify for a note? "Obstructive Sleep Apnea (OSA) is being managed with CPAP therapy. No new issues or concerns were reported. Continue CPAP therapy as prescribed."
A5. The medical record must support the level of care provided and meet the requirements of the policy. Provider Outreach and Education cannot pre-approve medical records.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Positive Airway Pressure (PAP) Devices

Q6. For HCPCS code A6593 (accessory for gradient compression garment or wrap with adjustable straps, not otherwise specified), if the claim is submitted and Medicare does not process or pay it correctly, can an appeal be filed? If so, what steps should be taken to resolve the issue?
A6. If the claim is rejected, the appropriate next step is to correct any claim errors and resubmit the claim. If you believe the claim was not reimbursed correctly, an appeal may be submitted with all documentation supporting the item billed, along with a request to review the payment issued. For claims without an established fee schedule amount, Medicare may use a gap-filling methodology to determine pricing. Additional information regarding Medicare pricing methodologies is available on the Pricing page of our website.

Resource: Noridian Medicare website > Fees and News > Fee Schedules > Pricing

Q7. Could you please provide guidance regarding nebulizers that are prescribed on an as-needed (PRN) basis for a beneficiary with a valid diagnosis?
A7. For Medicare claims, suppliers must obtain a valid Standard Written Order (SWO). The SWO must include the quantity to be dispensed for inhalation medications. If the quantity is not included on the SWO, the claim may be denied. PRN instructions are acceptable if the prescriber chooses to include frequency information; however, frequency of use is not a required element of the SWO. The required quantity to be dispensed must still be specified.

Resource: Standard Documentation Requirements for All Claims Submitted to DME MACs

Q8. If a Qualified Medicare Beneficiary (QMB) owns capped rental DME and no longer meets Medicare coverage criteria for the equipment, can the supplier bill the beneficiary for noncovered maintenance, servicing, or repairs?
A8. If a beneficiary no longer meets Medicare coverage requirements, Medicare payment for related services may not be available. For beneficiaries with QMB status, suppliers may not bill Medicare cost-sharing amounts (deductibles, coinsurance, or copayments). Beneficiary liability for noncovered services depends on the specific circumstances and applicable Medicare billing requirements. Review CMS QMB guidance and any applicable Advance Beneficiary Notice of Noncoverage (ABN) requirements before billing the beneficiary.

Resource: Noridian Medicare website > Billing, Claims, and Appeals > Qualified Medicare Beneficiary (QMB) Program

Q9. For orders containing an illegible practitioner signature, is a printed name alone sufficient to validate the signature or is a signature attestation statement also acceptable?
A9. A printed name accompanying the signature may be sufficient if it clearly identifies the individual. If the signer cannot be identified, CMS allows the use of a signature log or signature attestation statement to verify the signer.

Resource: Refer to the CMS Medicare Program Integrity Manual100-08, Chapter 3, Section 3.3.2.4, and the CMS Signature Guidelines for Medical Review Purposes for additional information.

Q10. For CPAP supplies, if a beneficiary is returning to Medicare coverage and is not new to Medicare, is a new SWO required? Additionally, is documentation of continued use and continued medical need (clinical benefit) required for the supplies, or do those requirements apply only to the CPAP device?
A10. For a beneficiary returning to Medicare, a new SWO is required for CPAP supplies. If the CPAP device is beneficiary-owned and not on file with Medicare, that information must also be provided. Documentation of continued medical need and continued use should support ongoing supply claims.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Positive Airway Pressure (PAP) Devices

Q11. What are the face-to-face (F2F) documentation requirements for PAP devices (E0601) and RADs (E0470, E0471)?
A11. The treating practitioner must perform and document a F2F evaluation that supports the diagnosis, severity of the condition, and medical necessity for the device. Review the LCD and Policy Article for the item to ensure all coverage, testing, and documentation requirements are met.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Positive Airway Pressure (PAP) Devices and Respiratory Assist Devices

Q12. Would a pantyhose compression garment be considered a unit used for the entire lower extremity? For example, if a beneficiary receives two knee-high compression garments and one pantyhose compression garment, would the beneficiary be ineligible for additional garments until the six-month replacement period has been met?
A12. Medicare allows three daytime garments or wraps per body area every six months. A pantyhose compression garment is considered a garment for both lower extremities. Therefore, if a beneficiary receives two knee-high garments and one pantyhose garment, they have reached the utilization limit for the affected lower-extremity body area(s) and may not be eligible for additional daytime garments until the next six-month period.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Lymphedema Compression Treatment

Q13. If the ABN was invalid at the time of delivery, can we retrieve the Power Wheelchair (PWC), obtain a valid ABN, and then re-deliver the same PWC as new equipment?
A13. A valid ABN must be completed prior to delivery. If the ABN was not completed accurately, a change in liability may not occur. Medicare does not allow this scenario.

Resource: Noridian Medicare website > Browse by Topic > Advance Beneficiary Notice of Noncoverage (ABN)

Q14. Coverage for hypertonic saline (J7131) became effective February 1, 2026; however, all claims submitted are denying. Can you provide guidance regarding the coverage requirements, documentation requirements, and billing criteria necessary for Medicare payment?
A14. HCPCS code J7131 requires an applicable Group 15 diagnosis code on the claim, as outlined in the Policy Article. In addition, the appropriate modifiers must be appended for correct claim processing. If the claim continues to deny after the required diagnosis code and modifiers have been included, contact the Supplier Contact Center for claim-specific assistance.

Resource: Noridian Medicare website > Browse by Topic > Nebulizers

Q15. What is the maximum number of days before a current supply prescription (Rx) expires that a doctor can sign the yearly renewal/recertification prescription? Where is this requirement located?
A15. Medicare does not establish a maximum number of days before an order expires that a renewal or recertification prescription may be signed. A routine refill prescription is generally not required for supplies provided on a recurring basis if the original order has not expired or exceeded the maximum number of refills. Instead, suppliers must comply with Medicare's refill request requirements and maintain documentation supporting continued medical need and refill requests. Also, stay attuned to local state laws regarding prescriptions. Refer to "Items Provided on a Recurring Basis and Request for Refill Requirements" below for more information.

Resource: Noridian Medicare website > Policies > Medical Director Articles > Medical Director Articles - 2025

Q16. We have a patient who is getting ready to reach their Reasonable Useful Lifetime (RUL) for both stationary and portable oxygen. Thirty-six months have been paid for both. We understand that once the RUL is reached, we need to obtain a new order and documentation showing continued use and benefit to continue services. When reviewing the testing, we found qualifying exercise testing from 2020. The patient was retested in 2022; however, they did not desaturate below 90% during that test. Would we need to have the patient retested to demonstrate the continued need for portable oxygen?
A16. When replacing existing oxygen equipment after the RUL with an identical item (same HCPCS), there is no new testing or face-to-face required. However, a new order is required. For HCPCS codes E0424, E0431, E0433, E0434, E0439, E1390, E1391, and E1392, a new written order prior to delivery (WOPD) is required.

Resource: Noridian Medicare website > Fees and News > Frequently Asked Questions (FAQs)

Q17. For spinal bone growth stimulators (E0748), if a beneficiary previously had a successful multi-level spinal fusion (for example, L4-S1) and later required an additional single level fusion (for example, L3) due to Adjacent Segment Disease (ASD), would that procedure be considered a multi-level fusion (L3-S1) and therefore meet the coverage criteria? Or should it be considered a single-level fusion, since it is only expanding the previous fusion by one level?
A17. If the current surgery only adds one level (L3-L4) to a previously successful L4-S1 fusion, it is generally considered a single-level extension, not a new multilevel fusion. The E0748 coverage criteria apply to multilevel spinal fusions involving three or more vertebrae. Therefore, this scenario would not meet coverage criteria. Denied claims must follow the appeals process and include supporting documentation.

Resource: Noridian Medicare website > Browse by DMEPOS Category > Osteogenesis Stimulator

Q18. How should ostomy skin barrier with flange (A4414) be billed for a patient with both a urostomy (Z93.6) and a colostomy (Z93.3) when the same wafer is used at both sites? We have tried multiple ways to submit the claims, but all methods are denied for either duplicate billing or overutilization because A4414 has a 20-unit monthly limit, even though the patient has two distinct ostomy sites requiring a total of 40 units.
A18. While Medicare recognizes that a beneficiary's supply needs may vary based on individual circumstances, quantities above the standard utilization parameters require additional medical review and supporting documentation. In this situation, a redetermination request is required. Submit documentation supporting the presence of both ostomy sites and the medical necessity of the additional quantity. The appeal allows the claim to be reviewed based on the beneficiary's specific clinical circumstances.

Resource: Noridian Medicare website > Billing, Claims and Appeals > Appeals

Q19. Is a new ABN required if there is no change in condition?
A19. An ABN may remain valid when all of the following are true:

• There is no change in the beneficiary's condition
• There is no change in the item or service
• There is no change in Medicare coverage expectations
• The same reason for expected noncoverage still applies
• The ABN is properly completed and was accepted before the item/service was furnished

In these situations, the original ABN can remain on file and continue to be used.

Resource: Noridian Medicare website > Browse by Topic > Advance Beneficiary Notice of Noncoverage (ABN)

Q20. Is there a time limit between the prior physician visit, the sleep study (performed within 12 months), and the Detailed Written Order (DWO) if the DWO is dated more than six months after the sleep study? In other words, does the order remain valid when there is a significant gap between these events?
A20. For items on Medicare's F2F and WOPD Required List, the beneficiary must have a qualifying visit with a treating practitioner within six months prior to the order date. For all other items not on the Required F2F and WOPD List, the order should be within 12 months prior to the date of service.

Resource: Noridian Medicare website > Browse by Topic > Documentation > Face-to-Face and WOPD Required List

Q21. Will Medicare cover use of a walker and wheelchair concurrently?
A21. A manual wheelchair will not be covered when a walker is billed for the same date of service because the mobility limitation criteria for the wheelchair are not met. If the beneficiary can meet their mobility needs with a walker, then the requirement that a wheelchair is medically necessary to accomplish mobility-related activities of daily living (MRADLs) in the home has not been satisfied. Therefore, coverage for the manual wheelchair would be denied.

Resource: Noridian Medicare website > Policies > Active LCDs > Local Coverage Determination (LCD) Manual Wheelchair Bases L33788

Q22. How old can a titration study be and still qualify a patient with OSA for oxygen coverage while meeting the time-of-need requirement for a patient who is new to Medicare?
A22. There is no defined age limit for the titration study in policy, but the study must support the patient's current need for oxygen and satisfy all OSA-specific qualification requirements.

Q23. For RAD compliance coverage beyond three months, is there a time period that defines "consistently"?
A23. Policy does not define a specific time period or usage threshold for the term "consistently." The treating practitioner is responsible for evaluating the beneficiary's ongoing use of the RAD and determining whether continued use is occurring on a consistent basis to support the medical necessity of continued coverage.

Q24. The patient received an Adaptive Servo-Ventilation (ASV) device (E0471) in July 2025. The patient has now been prescribed a Bilevel Positive Airway Pressure Spontaneous/Timed (BiPAP ST) device, which is also billed under HCPCS E0471. Can this device be covered?
A24. If Medicare has an E0471 on file, billing an additional item coded as E0471 will deny same or similar. Follow the appeals process and include all required documentation to support medical necessity. In addition, an ABN may be issued.

Resource: Noridian Medicare website > Browse by Topic > Same or Similar Chart

Verbal Questions Asked During ACM

No verbal questions were asked during the call.

Written Questions Asked During ACM

Q25. Do all nebulizer claims over 30 days require a day supply narrative, or only if it is for 90 days?
A25. A narrative is not required on the dispensing fee codes. In billing for the nebulizer dispensing fees, the 30-day dispensing fee is billed as Q0513 HCPCS code, and the 90-day dispensing fee is billed with Q0514 HCPCS code.

Q26. I have a power wheelchair order, and the doctor recommended a mobility evaluation but there is no mention of power in the face-to-face. The physical therapy (PT) evaluation rules out all lesser equipment and recommends a power wheelchair. Will the doctor's concurrence on the evaluation be sufficient for this power chair order?
A26. Provider outreach and education cannot pre-approve medical documentation. However, concurrence from the treating practitioner would be required for supplemental documentation is provided, such as PT or occupational therapy (OT) notes to meet policy.

Q27. If a sling is provided to a beneficiary following surgery in an outpatient surgery center and the beneficiary is discharged home the same day, can the sling be billed to Medicare for home use if the medical record does not explicitly state the beneficiary was discharged home?
A27: Medicare will pay for medically necessary, covered DME items on the date of discharge as long as the beneficiary goes to a payable place of service (POS), such as POS 12 for home. The notes do not specifically need to state the beneficiary was discharged to home as Medicare records will reflect a discharge date and location in the beneficiary's history.

Q28. We are having an issue with checking same/similar on the Noridian Medicare Portal (NMP). When the correct information is input, an error message appears stating a beneficiary name mismatch. The same information submitted, however, will pull up eligibility information for the patient. The patient lives within the jurisdiction, why is this occurring?
A28. This situation may occur when there is a beneficiary name and Medicare Beneficiary Identifier (MBI) mismatch. Please refer to the Supplier Contact Center for the appropriate jurisdiction to help resolve this situation.

Q29. Medicare did an audit on an enteral nutrition claim prior to payment, and a partial payment was made. The denial stated that the documents did not support the amount billed. We believe one line was denied in error, and one line was denied due to an error on the inventory in our system resulting in an overbilling of 0.05 per packet sent. We then noticed the wrong "kit code" (B4035) was billed instead of B4036. On the NMP, it does not allow us to perform a corrected claim, only a reconsideration. Can we correct the claim while doing a reconsideration?
A29. If redetermination rights have not been exhausted, a redetermination decision must be completed before a reconsideration request can be performed. Please refer to the Noridian Medicare website for more information on the appeals process.

Resource: Noridian Medicare website > Billing, Claims, and Appeals > Appeals

Follow-Up Question: Can we make changes to a claim on a redetermination?
Answer. This depends on the change. Adding or correcting modifiers, changing the date of service, etc., is allowed. However, to correct the HCPCS or add a HCPCS, it is recommended to resubmit the claim with the corrections required.

Q30. For a respiratory assist device (E0471) without a chronic obstructive pulmonary disease (COPD) diagnosis, what is the exact usage requirement? If the requirement is an average of four hours per day, over how many days is that average calculated?
A30. For RAD coverage beyond the initial three-month period, Medicare does not establish a specific usage requirement or define a set number of hours or days that constitute "consistent" use for beneficiaries without a COPD diagnosis. Continued coverage is based on documentation from the treating practitioner demonstrating that the beneficiary is consistently using the device and deriving clinical benefit from therapy. The treating practitioner is responsible for determining and documenting continued use and benefit.

Q31. We set up a patient with a CPAP July 19, 2019, but they weren't Medicare eligible until August 1, 2019, and we never billed Medicare for the device. Now we want to bill Medicare, do we need a new sleep study, or can we use the one from 2019? I know we would need a new F2F and WOPD but not sure if we can use the old sleep study.
A31. The sleep test must meet current coverage criteria and the requirements of the LCD/PA. If the sleep test does not meet current LCD requirements, a new sleep test would be required.

Q32. Are home titrations accepted for obstructive sleep apnea (OSA) for BiPAP, RAD, or oxygen?
A32. Based on the PAP LCD, home-based sleep tests are acceptable testing for PAP devices and RADs with a diagnosis of OSA. For beneficiaries with OSA, a qualifying oxygen saturation test may only occur during a titration polysomnographic study (either split night or stand-alone).

Q33. For a continuous glucose monitor (CGM) setup, if the patient just became effective with Medicare can the F2F be prior to the Medicare effective date?
A33. If the F2F visit was completed within the six months prior to initiating CGM for the beneficiary and the documentation includes all medical necessity criteria required by the policy, this would be acceptable.

Q34. Can an oxygen saturation test with OSA be done as a home titration, on an oximeter machine while using an oral appliance or CPAP?
A34. Per the oxygen LCD, for beneficiaries with OSA, a qualifying oxygen saturation test may only occur during a titration polysomnographic study (either split night or stand-alone).

Q35. Can the description for a concentrator be generic as "oxygen" on a WOPD?
A35. The WOPD can list a general description of the item, such as "portable" or "oxygen concentrator" is acceptable. That way it is known what type of oxygen is being ordered.

Q36. A patient had CPAP for one month, paid by Medicare, then it was returned. Three months later, the doctor orders the CPAP again. What months are the compliance counted from? Would the patient have to meet compliance before the CPAP can be billed again, for month two?
A36. In this scenario, the supplier can start billing in month two, and the patient will need to meet coverage criteria before month four can be billed for payment.

Q37. A patient qualified for a power wheelchair, however, was in a Skilled Nursing Facility (SNF), so the secondary insurance paid for a wheelchair or power wheelchair two years ago. Two years later, the patient is home and the chair needs repairs. Would Medicare pay for repairs on that chair?
A37. Medicare may cover reasonable and necessary repairs to beneficiary-owned equipment, even if Medicare did not originally pay for the wheelchair. Coverage depends on whether the beneficiary currently meets Medicare requirements, owns the equipment, the repair is medically necessary, and the repair is more reasonable than replacement of the item. Suppliers should maintain documentation supporting ownership of the wheelchair, continued medical need, and the repair being performed. If a claim is denied, suppliers may follow the appeals process and submit supporting documentation for review

Resource: Noridian Medicare website > Browse by Topic > Repairs, Maintenance and Replacement

Q38. For PAP coverage with an apnea-hypopnea index (AHI) of 5–14, must the physician specifically document "excessive daytime sleepiness" to meet the coverage requirement, or can documentation of daytime fatigue, tiredness, naps, or an Epworth score of 10 be used to satisfy the 'excessive daytime sleepiness' requirement?
A38. Medicare does not specifically require the physician to use the exact phrase "excessive daytime sleepiness." The medical record should support that the patient has symptoms consistent with excessive daytime sleepiness. The safest documentation is for the physician to explicitly document "excessive daytime sleepiness" or clearly describe symptoms demonstrating it (e.g., daytime somnolence, unintended dozing, frequent naps, hypersomnolence).

Q39. Can a patient qualify for initial Medicare oxygen coverage if they have to stay on oxygen during the exercise test and their oxygen level drops with activity?
A39. This could be possible if it is well documented that the beneficiary could not be taken off oxygen to perform all parts of the three-part test.

Q40. E2512 (speech-generating device mounting system or an electrical wire bootlace ferrule) is not on the PDAC site or fee schedule but all our claims are paying the same allowed amount. Can you tell me where Medicare is getting the price from? We have it sent up as an IC code and to pay off Manufacturer's Suggested Retail Price (MSRP).
A40. When a fee schedule amount is not available, Medicare contractors utilize gap-filling pricing methodology. Under this process, the DME MAC establishes an allowance based on available pricing information.

Resource: Noridian Medicare website > Fees and News > Fee Schedules > Pricing