Delivery Dilemma Solved

On July 22, CMS issued instructions specifically allowing suppliers to deliver oximetry testing equipment on behalf of Medicare Independent Diagnostic Testing Facilities (IDTFs). The instructions explain the conditions and logistics of HME suppliers' involvement in assisting beneficiaries with obtaining home oxygen therapy qualifying testing results.

There are several new technologies available in the market that facilitate an IDTF's ability to test a beneficiary, in the beneficiary's home, for oxygen saturation levels. These test results can then be used to qualify the beneficiary for coverage of home oxygen therapy.

Because there are strict rules about Medicare Part B DMEPOS suppliers not being able to test beneficiaries, there has been considerable confusion about the arrangements suppliers can have with IDTFs and companies that sell or lease these units.

The CMS instruction provides clarity to suppliers, IDTFs and physicians who prescribe oximetry testing for their beneficiaries, to determine whether the beneficiary qualifies for oxygen therapy under the Medicare coverage criteria.

CMS has provided a series of parameters that all suppliers should understand and comply with when delivering the testing units to the beneficiary's home. Following is an explanation of the criteria:

• First, as with all lab tests, the beneficiary's treating physician must order an overnight pulse oximetry test. Importantly, Medicare will only pay for the tests when the test units are used for purposes of overnight testing. Spot testing and testing a beneficiary during exercise are not covered tests. (Be sure to check with other payer sources about their particular coverage policies for the various types of tests.) The reason that CMS limited coverage to overnight testing is primarily because of the difficulty many beneficiaries had in obtaining access to an IDTF for overnight testing.

• Second, the test must be “performed under the direction and/or instruction of a Medicare-approved IDTF.” According to CMS, it is the beneficiary who must self-administer this test. Therefore, CMS requires that the IDTF provide clear written instructions to the beneficiary on the proper operation of the test equipment and must include access to the IDTF in order to address other concerns that might arise.