CQRC makes voice heard

WASHINGTON – The Council for Quality Respiratory Care used a recent Request for Information from CMS to push for clear, objective clinical data elements for oxygen that are consistent with existing CMS-developed “templates” to ensure access to care for home respiratory patients. 

In its comments on “Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs, the CQRC also urges CMS to issue clear guidelines about what to expect after the COVID-19 public health emergency ends so that patients continue to receive these services based on their existing documentation order. 

"Currently, CMS has yet to issue guidance as to how it plans to address these patients regarding the documentation and audit processes,” the CQRC states. “Requiring all these patients to return to their doctors, be tested again, receive a new prescription, and submit new documentation will overload the already stressed healthcare system.”   

The CQRC also commented on health care worker and provider well-being, saying that Medicare’s reliance on outdated, paper medical record reviews leads to high denial rates as a result of inconsistent document standards.  

“Suppliers simply cannot provide medically necessary services when they are not reimbursed because contractors determine that physician notes do not meet a standard that has not been shared with the physicians making those notes,” the CQRC states. 

CQRC proposes the agency instruct contractors to streamline the process by using CMS digital “templates” with standardized clinical data elements instead of paper records. CMS currently maintains such a template on its website that could be easily adapted by Medicare contractors instead of requiring home oxygen suppliers to provide a patient’s medical record, which may or may not include the subjective “magic words” that the contractor requires for reimbursement. 

“Doing so will reduce burden, set the agency on a clear path to the use of digital health technology that will reduce burdens on providers and suppliers, and protect access to a medically necessary therapy that allows individuals to remain in their homes and communities, and reduce hospitalizations and the need for institutional-based care,” said CQRC.