Ask the PSC MDs
For this month's column, we turn to oxygen, specifically oximetry testing and the Web-based services provided by independent diagnostic testing facilities (IDTFs). There has been tremendous growth in the use of these services over the past year. As more suppliers use this approach, the number of questions increases. Based on questions received by the medical directors on IDTF, we published an article in June 2006 to remind suppliers of their limited role as participants in this testing process. As might be expected, this article generated it's own questions. We will address a few this month.
Q. Why can't suppliers perform their own oxygen testing?
A. CMS Pub.100-3, section 240.2.C, requires all claims for home oxygen therapy to be supported by valid qualifying test results "performed by a qualified provider or supplier of laboratory services." This section also states, "A DME supplier is not considered a qualified provider or supplier of laboratory services for purposes of these guidelines."
Q. Who may order oximetry testing?
A. The beneficiary's treating physician must order an overnight pulse oximetry test.
Q. Are there any special requirements that an IDTF must meet in order to perform a valid test?
A. According to the Code of Federal Regulations (42CFRS 410.33) and CMS Manual System, Pub. 100-8, Medicare Program Integrity Manual Chapter 10-Healthcare Provider/Supplier Enrollment, Section 5, there are specific requirements that must be met for an applicant to be enrolled in Medicare as an IDTF. All IDTFs, whether they provide multiple types of tests or only self-administered pulse oximetry testing must meet all the requirements for enrollment into the Medicare program.
Q. How may DMEPOS suppliers participate in these IDTF-based testing programs?
A. A DME supplier or other shipping entity may deliver a pulse oximetry test unit and related technology to a beneficiary.
Q. Are there any activities that a DMEPOS supplier is prohibited from doing as part of IDTF-based testing?
A. Yes, there are several limitations:
- The DME supplier does not perform or participate in the conducting of the test or create instructions regarding the test for the beneficiary.
- The test unit is sealed, tamper-proof and only accessible by the IDTF who transmits the information to the treating physician. The DME supplier may use related technology to download and transmit those results to the IDTF, but the DME supplier may in no way access or manipulate the test results.
- No shipping and/or handling charges may be charged to or paid by a beneficiary because these charges are included in the fee schedule payment for the overnight pulse oximetry test.
- It is important to note that supplier involvement in the delivery of oximetry devices to perform tests used to determine Medicare coverage for home oxygen is limited to sleep oximetry tests. Oximetry test results obtained through a similar process while the beneficiary is awake, either at rest or with exercise, may not be used for purposes of qualifying the beneficiary for home oxygen therapy.
- Suppliers are also cautioned that sleep oximetry testing must be based on a request that is initiated by the treating physician. It is inappropriate for a supplier or IDTF to initiate a contact with the physician either directly or through the beneficiary to request, suggest, or otherwise seek an order for home oximetry testing.
Consult the CMS, DME PSC or DME MAC Web sites for additional information on this topic.