Oxygen audits: Ready for relief

Thursday, January 19, 2012

ALEXANDRIA, Va. - For providers struggling with oxygen audits, CMS's promise to modify certain aspects of the process has been welcome news.

"We'll take anything we can get," said Robin Powers, billing supervisor for Friendship Home Medical Equipment in Wise, Va.

Earlier this month, AAHomecare announced CMS plans to focus on auditing oxygen claims with initial dates of service within the last few months, rather than the last few years. It also plans to give providers 45 days instead of 30 days to respond.

Provider John Kaiser says that extra time will make all the difference. Recently, he received letters requesting documentation on several claims from 2008-2009. The date he received the letters: Jan. 12; the date CMS sent the letters: Dec. 31.

"That gives us only two weeks to respond," said Kaiser, president of Walnut Medical in Johnston, Pa. "Forty-five days would be helpful when it takes them two weeks to get their stuff out."

Despite these modifications, some problems will persist, stakeholders predict. For example: Auditors may look at more current claims, but what if those claims are for continued use of oxygen, meaning the documentation goes back years?

"Even if the date of service is today, I don't have that stuff, or the stuff that I have no longer meets the criteria," said Kim Brummett, vice president of contracting and reimbursement for Advanced Home Care in Greensboro, N.C. and a member of AAHomecare's Audit Task Force. "Back then, all we needed was a CMN and proof of delivery."

CMS has also indicated it will revise local coverage determinations (LCDs) to provide clear guidance on how frequently doctors need to document continued use of oxygen, said Walt Gorski, vice president of government affairs for AAHomecare.

"That's an issue that has continued to stymie providers," he said. "Nowhere in the LCDs is there a continued use requirement, but there is a vague reference to it in the Program Integrity Manual."

That would be key for Powers, who has appealed all the way to the administrative law judge (ALJ) level for a claim for continued use of oxygen.

"They said we have to have a CMN every year," she said. "No you don't; that's not in the policy."



Kim Brummett is mistaken when she claimed "Back then, all we needed was a CMN and proof of delivery." The LCD has always stated that proof of medical necessity is needed i.e. Dr. notes, test results, etc... There is a difference between what you need to bill and what you should have in a patients chart if you get audited. DME providers that take the easy path to getting paid make it much harder on providers that ask a referral source for complete documentation.<br />

Ten years ago the LCD was about 2 pages and very uninformative with regards to actual documents needed to prove medical necessity. Now its like 20 pages long. The problem is that Medicare and other insurance are asking non-clinical personnel to make business decisions based off clinical information.

Who in their right ming would provide home O2 based upon logical business decisions. Remimursements are low. Audits are high. Paperwork requirements are excessive. Staffing costs are not in line with reimbursements. Seriously, you would have to be a moron to think an investment in a home medical equipment company focused on respiratory care was going to provide a reasonable return on your investment.