Upcoming Educational Opportunities About Oxygen Policy Changes

Published in Government Relations on June 06, 2022

Have you been able to keep up with the oxygen policy updates? If the answer is no, we understand why! It’s due to all the confusion with the policy changes on top of dealing with the PHE. The latest announcement is that CMS is delaying the implementation date to January 3, 2023. Yes, that is correct. The implementation date has changed to January 2023 to be in alignment with the elimination of the CMN. Click here to read more.

Even though the initial implementation date has changed from June 2022 to January 2023 now, Ronda Buhrmester, Sr. Director of Payer Relations and Reimbursement, will move forward with offering education to the industry. Here are some opportunities to learn about the oxygen policy changes:

Click the links above to learn more and register.

In addition, on Friday, June 3, 2022, the DME MACs made a revision to the CMS-1744-IFC regarding the CMN/DIF instructions during the PHE:

CMN and DIF Instructions - Oxygen (Form CMS 484.3) and External Infusion Pumps (Form 10125)
CMS-1744-IFC stated that CMS would exercise enforcement discretion for clinical indications of coverage for the oxygen NCDs and LCDs during the PHE. Numerous fields on the Certificate of Medical Necessity (CMN) for oxygen are directly related to the clinical indications. After carefully reviewing the CMN and the related claims processing issues that would result from having missing information or having clinical information for which the form was intended, CMS has determined that requirements for a CMN for oxygen claims will not be enforced during the COVID-19 PHE. The same concerns that apply to the oxygen CMN also apply to the External Infusion Pump (EIPs) DIF; therefore, the requirements for a DIF for EIP claims will also not be enforced. Suppliers should follow the guidance in the Claim Instruction section above for oxygen and EIP claims.

There is no requirement to submit a CMN or DIF during the PHE for oxygen or EIPs. If CMNs or DIFs are not submitted, suppliers must use the CR modifier and COVID-19 narrative for any oxygen or EIP claims submitted during the COVID PHE. CMNs or DIFs are not required regardless of the diagnosis or etiology necessitating the use of the CMN-related or DIF-related DME. Use of the CR modifier and COVID-19 narrative simply reflects that the claim was submitted during the COVID PHE.

Click here to learn more.


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  1. billing & reimbursement
  2. education
  3. hme
  4. vgm
  5. vgm government

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