CMS details billing policies

Saturday, February 28, 2009

WASHINGTON--CMS in January released billing details for capped oxygen patients. The industry’s reaction: It’s a day late, and to some, a dollar short.

In its Jan. 27 listserv message, CMS detailed how to replace equipment after five years and provide contents.

“In general, I thought it provided clarity on some of the billing issues we’ve had,” said Cara Bachenheimer, senior vice president of government relations for Invacare. “But, really, this should have been out in December. They didn’t re-invent the wheel.”

The message came more than three weeks after the 36-month cap on Medicare oxygen reimbursement kicked in Jan. 1.

The industry has known for some time that providers could, with the beneficiary’s consent, supply new oxygen equipment after five years, starting a new rental period. But they weren’t sure of the logistics. CMS’s message instructs providers to submit a claim using the RA modifier; file a new certificate of medical necessity (CMN); and maintain delivery documentation.

One thing CMS doesn’t require: new testing.

“That’s a huge silver lining,” said Kelly Riley, director of The MED Group’s Respiratory Network. “Getting patients retested would have been the straw that broke the camel’s back.”

CMS’s message also addressed whether providers have to deliver oxygen contents each month to bill for them each month - they don’t. They can deliver up to three months’ worth of contents at a time.

Getting paid for replacing equipment and providing contents may remain a challenge.

“Because this isn’t an official program transmittal, do the DME MACs have their systems programmed to accept claims for replacing equipment and providing contents?” Bachenheimer said.

For some industry sources, CMS’s message didn’t go far enough.

“We feel CMS is still ambiguous, when it comes to changing equipment during the five-year reasonable useful lifetime,” said Wayne Stanfield, executive director of NAIMES. “In one sentence, they state that changing equipment doesn’t start a new five-year period; in another sentence, their wording implies that it does.”