CQRC Urges Adoption of Standard Clinical Data Element Template  


October 25, 2023

Supplemental oxygen community urges Medicare documentation reforms to protect patient access to home respiratory care 

Washington, D.C. – The Council for Quality Respiratory Care (CQRC) – a coalition of the nation’s leading home respiratory therapy providers and manufacturing companies – is recognizing Respiratory Care Week by urging the Centers for Medicare & Medicaid Services (CMS) to require Medicare contractors to use a standard clinical data element template for supplemental oxygen in order to ensure beneficiary access to care and protect prescribers and suppliers from unwarranted and burdensome audits. 

In a letter sent to CMS on October 10, home respiratory care stakeholder groups – including CQRC, AAHomecare, American Association for Respiratory Care, American Thoracic Society, American College of Chest Physicians (CHEST), and The VGM Group – urged CMS to require Durable Medical Equipment (DME) Medicare Administrative Contractors (MAC) and other contractors to use the existing CMS clinical data element template. According to the stakeholders, CMS efforts to improve the DME system should focus on identifying “agreed upon clinical data elements and a requirement that the DME MACs and other contractors accept these data elements in lieu of medical records when reviewing audited claims.” They note that this modernization would better align Medicare with the electronic submission of information that commercial payers already use. 

The groups wrote, “The problem that the community would like CMS to address is the Medicare program’s reliance on medical record notes. This concern stems from the fact that the contractor has not focused on the actual data elements, but rather on how to establish a prior authorization electronic interface, which is not the intent of the clinical template as we understand it. With the ending of the pandemic, the elimination of the Certificate of Medical Necessity, and the initiation of audits, not addressing this central problem will create a costly and unnecessary burden that without having any objective documentation for the appeals process could impact beneficiaries directly.” 

Earlier this year, 14 bipartisan House lawmakers sent a letter to the CMS Administrator Chiquita Brooks-LaSure also urging the agency to clarify Medicare documentation requirements for supplemental oxygen and adopt a standardized template for documenting patient need. 

“CMS already created the oxygen clinical data element templates which are more practical in assessing coverage needs. We therefore urge CMS to require contractors to use these templates, along with the standard written order in lieu of medical record notes when determining medical necessity,” the lawmakers wrote to CMS. 

The current process for prescribers ordering supplemental oxygen for their Medicare patients recognizes only a physician’s medical record notes as the source for establishing if a patient needs a device. This poses a significant administrative burden on healthcare providers, while also potentially putting patients at risk for care denials if the “right” words favored by a certain contractor are not included. Physicians, however, write medical notes specifically to inform a patient’s clinical care plan, not to satisfy contractor audits, underscoring the importance of maintaining a standardized template for supplemental oxygen. 

“In honor of Respiratory Care Week, CMS should heed the warnings of bipartisan lawmakers and respiratory care stakeholders alike and focus on the clinical data elements within the supplemental oxygen template to protect the interests of beneficiaries and all stakeholders involved in the Medicare program,” said Dan Starck, Interim Chair of CQRC. 


Media Contact: 

Ellen Almond