Ronda's Reflections on Four Hot Topics

Published in Member Communities on October 01, 2025

By Ronda Buhrmester, Senior Director of Payer Relations, VGM & Associates

Read about key topics affecting the DME industry, including upcoming NCD implementations, oxygen equipment audits, lymphedema garment compliance, and PTAN billing tips. 

1. Upcoming NCD Implementations  

The NCD for NIPPV for chronic respiratory failure caused by COPD is set to be implemented on Oct. 22, 2025. With the upcoming implementation date, we do know the DME MAC medical directors are diligently working on a local coverage determination (LCD) that will be opened up for public notice and comment. 

Recently, an MLN article was released that included ICD-10 diagnosis codes with the coverage determination. 

Watch for a webinar to be announced with VGM once the LCD is released. In the meantime, log into the members-only portal to view more information on NIPPV in the Home for the Treatment of Chronic Respiratory Failure Consequent to COPD.

2. Oxygen Equipment Audits 

Oxygen equipment continues to be under scrutiny with audits. The top error rate continues to be that the medical record documentation does not support that the treating practitioner has evaluated the results of a qualifying blood gas study performed. 

There are a few options available to meet this criterion as outlined in this article. The most convenient and easiest method is one we as suppliers have control of, and that is adding a statement to the SWO. Suppliers can complete the entire SWO except for the treating practitioner’s signature. All that needs to be done is adding a statement, such as, “I have reviewed and evaluated the oxygen test results performed on MM/DD/YYYY.” Be sure to also keep a copy of the actual test results in the patient’s medical record, as this must be included with the audit. 

3. Lymphedema Compression Garments Compliance 

For those suppliers offering lymphedema compression garments, we heard that these are under the TPE audit program with the DME MACs. This is the time to perform self-audits to ensure the coverage requirements are met. 

4. PTAN Billing Tips 

Compliance with the PTAN billing number is of the utmost importance because of the CMS oversight with the enrollment contractors. Here are a few tips to closely monitor, even though all 30 supplier standards are a must: 

• Make sure there is a current liability insurance certificate on file with the enrollment contractor. DO NOT wait for them to come to you because this is a risk of revocation that could cause recoupments. 
• Have direct contact information for the enrollment contractor. Whomever is in charge of handling the PTAN compliance, the enrollment contractor needs the direct phone number and email address. This will help avoid any issues with staff thinking it’s a scam caller or not getting the message. 
• Have a written policy for the complaint log. Make it simple; however, be sure to have a written policy. 
• Store hours need to be visible, and the store must be open during the hours that are posted. Store hour signage must be permanent and should not have a temporary look, such as using tape to hold up a sign. 
• Be prepared for a revalidation and unannounced site inspection.  

For any questions, please reach out to me at Ronda.Buhrmester@vgm.com.