Home Respiratory Community Unites to Urge Removal of Medicare Barriers to Accessing Home Oxygen Therapies

CQRC joins 13 other respiratory care stakeholders in urging CMS to require objective documentation to establish medical necessity

WASHINGTON, DC – The Council for Quality Respiratory Care – a coalition of the nation’s leading home respiratory therapy providers and manufacturing companies – today united with 13 other home respiratory care leaders in sending a letter to the Centers for Medicare & Medicaid Services (CMS) in response to last week’s National Coverage Decision (NCD) announcement, Home Use of Oxygen and Home Oxygen Use to Treat Cluster Headaches. In the letter, the groups commend CMS for expanding access to home respiratory care during the COVID-19 pandemic while asking CMS to reform the current documentation and audit requirements to ensure access to care for Medicare beneficiaries is not put at risk.

Excerpts from the letter to CMS Administrator Chiquita Brooks La-Sure include:

“Based on the collective experience of our organizations, we ask that CMS eliminate medical record review and accept the clinician prescription/Standard Written Order as the required documentation for establishing medical necessity, as it does for other prescription medications. Alternatively, along with the prescription, CMS could require clinicians to complete the existing supplemental home oxygen templates that would constitute the sole documentation to establish medical need and be sufficient for medical necessity review.”

“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.”

“Eliminating medical record review and contractor discretion in favor of Standardized Written Orders and templates to document medical necessity would protect against fraud and abuse, reduce the burden on clinicians and suppliers, and protect access for beneficiaries. The goal of medical necessity review is to protect the federal government and beneficiaries from fraud. Yet, this well-intentioned program has morphed into an assessment of clinician charting that does not identify fraud or abuse. Without clear, objective standards for review, it will become difficult for suppliers to continue filling clinician prescriptions for beneficiaries. It is time to fix this broken system and make sure that beneficiaries maintain access to these important home oxygen therapies.”

In addition to CQRC, the letter is signed by AA Homecare, Allergy & Asthma Network, Alpha-1 Foundation, American Association for Respiratory Care, American Lung Association, American Thoracic Society, American College of Chest Physicians, COPD Foundation, Dorney-Koppel Foundation, Pulmonary Fibrosis Foundation, Respiratory Health Association, U.S. COPD Coalition and VGM & Associates.

To read the full stakeholder letter, CLICK HERE.

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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.