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Navigating the New CMS Landscape with the HMV and RAD Decision Memo for COPD

Published in Member Communities on July 02, 2025

Ronda BuhrmesterBy Ronda Buhrmester, Sr. Director of Payer Relations and Reimbursement, VGM & Associates

On June 9, 2025, CMS released the implications of the newly finalized National Coverage Determination (NCD) for home mechanical ventilation (HMV) and respiratory assist devices (RAD). While the final NCD has an effective date of June 9, 2025, implementation instructions are yet to come!

The final NCD introduces expanded coverage for RADs and HMVs for patients with chronic respiratory failure due to COPD.

Key changes include: 

  • Clearer Initial and Continuing Coverage Criteria: CMS now outlines specific PaCO₂ with an arterial blood gas (ABG) and continued usage metrics for both RADs and HMVs. 
  • Compliance Demands: New documentation, usage tracking, and patient re-evaluation requirements will increase operational oversight—without added reimbursement. 
  • Hospital Discharge Provisions: Immediate post-discharge coverage is available for patients meeting defined clinical criteria. 
  • Grandfathering: Existing patients on HMV and RADs for COPD are grandfathered in.  
  • MAC Discretion: For cases outside the NCD scope, the DME Medicare Administrative Contractors (DME MACs) retain authority to determine coverage. 

Emphasis needs to be on the importance of proactive education and compliance monitoring with referral sources, staff, and patients. Suppliers are encouraged to prepare for increased documentation demands, patient re-evaluations, and tighter monitoring—without additional reimbursement. 

As the industry awaits further CMS instructions, one message was clear: educate, adapt, and stay ahead. 

We recently held a webinar with myself and industry experts Kim Cuce’, Noel Neil, and Zach Gantt about the key changes of this decision, the operational and financial impact on DME suppliers, and actionable strategies to navigate the new landscape. Click here to view the recording. 

For any questions, please reach out to me at ronda.buhrmester@vgm.com. 

TAGS

  1. billing & reimbursement
  2. cms
  3. oxygen
  4. reimbursement
  5. respiratory

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