Keeping Up with Oximetry Testing Rules

When you entered the home care field, you probably had images of providing care and comfort to those in need. Most of us never imagined that in order to assure access to care for those we serve, we would need to be just as cognizant of words like “transmittal,” “advisory opinion” and “bulletin” as we are of the words “concentrator,” “conserver” and “transfill.”

Although sifting through policy, transmittals and Office of Inspector General opinions is not something we look forward to, it must be done. And that information must then be disseminated to those sending orders for the patient's care.

One important transmittal has made it easier for HME suppliers and physicians to obtain oxygen-qualifying overnight oximetry test results.

CMS Transmittal 173, published in August 2005, allows the HME supplier (or other shipping entity) to deliver a sealed, tamper-proof oximeter to the patient's home on behalf of an Independent Diagnostic Testing Facility. This process can only happen after the patient's physician has ordered an overnight oximetry test.

CMS is very clear that the physician — not the provider — must request the test. However, providers are permitted to contact the physician regarding the need for testing in certain circumstances, for example: when recertification is due, when testing is required due to change in insurance, when the initial test was invalid, i.e., not done with patient in a chronic stable state, or within two days of discharge from a hospital.

Providers who have patients enrolled in disease management-type programs may continue to communicate with the physician in regard to findings on ordered clinical assessments.

A recent OIG advisory opinion strongly states that HME companies may not perform free pre-screening oximetry tests for patients. It is also prohibited for a company to set up oxygen for free while waiting for a qualifying test.

In the event that the patient must be set up on oxygen without the qualifying test, the provider must give the patient an Advanced Beneficiary Notice advising that the services provided will not be covered because they do not meet the payment coverage rules set by Medicare.

The policy issued by CMS states that the beneficiary may self-administer home- based overnight oximetry tests under the direction of the IDTF. Because the beneficiary self-administers the test, the IDTF must provide clear, written instructions on proper operation of the equipment, and provide a mechanism for the beneficiary to address questions to the IDTF.