CQRC: Medicare’s CMN Announcement for DME Underscores Need for Standardized Oxygen Template

Respiratory care providers stress importance of adopting standardized template to eliminate unfair denials due to use of ambiguous patient medical records

WASHINGTON, DC – In response to the Centers for Medicare & Medicaid Services’ (CMS) decision to discontinue the use of Certificates of Medical Necessity (CMN) for Durable Medical Equipment (DME), the Council for Quality Respiratory Care – a coalition of the nation’s leading home respiratory therapy providers and manufacturing companies – stressed the urgent need for Medicare to adopt a standardized oxygen template to confirm a patient’s medical necessity for supplemental oxygen supplies and services.

On August 18, CMS announced it will be discontinuing the use of CMNs and Durable Medical Equipment (DME) Information Forms (DIFs) for claims with dates of service on or after January 1, 2023.

“We applaud CMS’ attention to addressing the administrative burden placed on Medicare providers through unnecessary and time consuming paperwork requirements and support the Administration’s efforts to improve access to quality, affordable care by better enabling patient access to needed medical supplies,” said Crispin Teufel, CQRC Chair. “However, we have increased concerns that the patient medical record now serves as the sole documentation for determining medical necessity. Today’s announcement underscores the urgent need for a standardized oxygen template to ensure patient access to supplemental oxygen supplies is not unfairly restricted.”

Data show that the use of the medical record by Medicare contractors leads to improper denials based on documentation issues opposed to the lack of medical necessity. In fact, between 2016 and 2021, CMS CERT data indicates that less than one percent of the oxygen improper payment rate was due to patients not meeting Medicare’s medical necessity requirements.  During that period, the CERT has also reported that 72 to 99 percent of the oxygen improper payment rate was due to problems with the ordering clinicians’ documentation.

Earlier this month, 22 bipartisan members of Congress wrote a letter to HHS and CMS leaders in support of reforms to the home oxygen therapy benefit, which supports Medicare beneficiaries with acute respiratory conditions who require supplemental oxygen. The lawmakers asked CMS to ensure that Medicare contractor documentation requirements are consistent and standardized though the use of a clear, objective template. Lawmakers called for the template to clearly set forth the required information to demonstrate medical necessity without having to review pages and pages of individual clinician medical records.

In a letter signed by 14 stakeholder groups to CMS last October, the groups wrote, “To achieve CMS’s goals of providing beneficiaries with access to supplemental oxygen within in their homes and communities, it is necessary that suppliers be allowed to fill clinician’s prescriptions with the assurance that they will be reimbursed, just as pharmacists are when they fill drug prescriptions. Given the complexities of the medical record and differing clinician documentation preferences, medical record review is not optimal and should be avoided. Using the Standard Written Order and CMS’s existing templates would provide uniformity and certainty, while eliminating inconsistencies, in the review of individual claims.”

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About the Council for Quality Respiratory Care
The CQRC is a coalition of the nation’s seven leading home oxygen therapy provider and manufacturing companies. To learn more, visit cqrc.org and follow CQRC on Twitter at @TheCQRC.