BALTIMORE — Getting paid for oxygen is no easy task these days, judging by the questions on a joint CMS-DME MAC CERT call last week. Members of the CERT (Comprehensive Error Rate Testing) Education Task Force held a teleconference Feb. 3 to answer questions on oxygen coverage, testing requirements, CMNs and documentation — and there was no lack of them.
Representatives from the four DME MACs answered a dozen questions based on common claims errors, then spent the rest of the 90-minute call responding to live queries with help from Dr. Paul Hughes, the medical director for Jurisdiction A.
According to officials, there are multiple requirements that must be documented in order to justify reimbursement. While many are listed in the local coverage determination, others come from the national coverage policy, CMS manuals, regulations and statutes. Oxygen suppliers must be knowledgeable about all of them, the MAC reps emphasized — and in the event of an audit, "all applicable reimbursement criteria must be met and sufficient documentation demonstrating eligibility must be present in the record."
Written answers to more than 60 questions submitted before the call included the following:
Q: What is the responsibility of the provider for patients who are traveling outside the U.S.?
A: The supplier is not responsible to furnish oxygen for a patient that travels or resides outside the U.S.
Q: We received a medical review letter and denial because we don't have documentation that the patient was seen 30 days prior to initial setup. We have tons of documentation, just not within 30 days. We had money taken back on this patient. Can we have them see their doctor and be retested to re-qualify? Would we start a new 36 months cap rental period or start with the next billing month that we would have billed?
A: Yes, they can see their doctor and be retested to re-qualify. A new cap rental period would not begin in this situation.
Q: If a patient wants to switch suppliers due to poor service, but 36-rental payments have already been paid, can the patient switch suppliers?
A: Yes, the beneficiary has the option of switching suppliers; however, it may be difficult for the beneficiary to locate a new supplier willing to service them, given the new supplier will not receive any additional rental payments. However, if the beneficiary believes their supplier is not following supplier standards they have the option of reporting the supplier to 1-800-MEDICARE.
Q: When a patient switches to my company from another, do I need to get a CMN or just an order confirmation if I have a copy of the original CMN?
A: A revised CMN must be completed and kept in your files.
Q: In an audit, is the CMN considered a detailed written order when section C is filled out properly?
A: Yes, the CMN can be considered a detailed written order, but the CMN is not a substitute for Medical records from the treating physician.
Presenters said a written transcript of the call would be posted on the CMS CERT web page at www.cms.gov/cert (under the "Providers" tab) two weeks after the call. A replay will also be available on the DME MAC web sites.
