Medicare Should Protect Patient Access to Life Sustaining Home Respiratory Therapy After the COVID-19 Public Health Emergency Ends in May


To ensure continued access to home respiratory care, patients and providers urgently need a transition period and a clear, standardized template for demonstrating medical need

WASHINGTON – Today the Council for Quality Respiratory Care – a coalition of the nation’s leading home respiratory therapy providers and manufacturing companies – called for greater steps to protect America’s home respiratory patients, including the more than 1 million Americans who rely upon supplemental oxygen. They urged the federal government to implement policies so that patients receiving supplemental oxygen, home sleep therapy, and non-invasive ventilators do not experience barriers to maintaining access to these life-sustaining therapies due to new paperwork requirements that are set to take effect when the COVID-19 Public Health Emergency (PHE) ends on May 11.

“The public health emergency declaration went a long way towards ensuring the more than 1.5 million patients who rely on supplemental oxygen, non-invasive ventilation, and other forms of home respiratory care can access the critical, life-preserving care they need,” said Crispin Teufel, CQRC Chair. “While the end of PHE was inevitable-and the advance announcement is welcome-home respiratory patients and providers need more clarity and support to prevent potentially dangerous delays in care.”

The home respiratory community is calling for a transition period with clear expectations that outline what documentation suppliers must have obtained from physicians so that patients who have been prescribed home respiratory care can continue receiving these treatments.

Specifically, the CQRC joins others in the home respiratory community in urging the Medicare program to avoid requiring patients who received home respiratory therapies during the PHE to schedule new doctors’ appointments and get a second set of tests just to create paperwork that the government suspended during the PHE.

“If all patients will need to be requalified, it will cause serious patient access issues and create enormous demand for already-overburdened physicians,” continued Teufel. “There are simply not enough physicians to re-evaluate and re-test the more than 1 million patients who rely upon these therapies during the next 100 days.”

In addition, when the PHE ends, CMS plans to implement a new policy that will make it more difficult for physicians and suppliers to demonstrate that a patient medically requires supplemental oxygen therapy. Based upon historic contractor practices, if CMS were to implement this medical record-only review, it is likely that Medicare contractors would deny between 75 and 90 percent of claims because they may not find the physician’s medical record to support the physician’s decision to prescribe the therapy.

To further help streamline access to care in the months and years ahead, the home respiratory community is calling for the Centers for Medicare & Medicaid Services (CMS) to develop an objective standard clinical data elements oxygen template that clearly outlines information needed to support each claim, thereby lowering burden on providers and preventing inappropriate denials.

Teufel added, “During the pandemic, we have learned the critical role that home respiratory therapy plays in keeping individuals out of the hospital, at home, and in their communities. We welcome the opportunity to work closely with the Administration and the Congress to make sure that the transition from the pandemic to the new normal does not cause those who rely upon home respiratory therapies to lose access to the treatment options prescribed for them. It is important that they can continue to actively engage with their families, friends, and neighbors.”


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 and follow CQRC on Twitter at @TheCQRC.