Policy Priorities

CQRC members provide patient-centered care in the home to individuals who require supplemental oxygen, home sleep, and home non-invasive ventilation therapies. CQRC members have expanded access to these home therapies to enable more beneficiaries to receive care at home instead of in the hospital. CQRC is committed to protecting continued access to individuals who need supplemental oxygen therapies by strengthening the Medicare benefit.

Pass the Supplemental Oxygen Access Reform (SOAR) Act (S. 1406/H.R. 2902) to Address Barriers to Care, Protect Against Fraud and Abuse, and Lock-in Savings from Competitive Bidding

The CQRC strongly supports the passage of the bipartisan SOAR Act, which would implement Medicare reforms and establish protections for beneficiaries who require supplemental oxygen modalities to manage their respiratory or pulmonary conditions. This would help more patients access oxygen therapy and live more active, independent lives by:

  • Locking in savings for supplemental oxygen obtained from Medicare’s competitive bidding program,
  • Restoring access to medically necessary liquid oxygen by creating a separate payment system for liquid oxygen,
  • Protecting access in non-competitively bid areas by making Medicare’s blended payment rates permanent,
  • Ensuring adequate reimbursement for respiratory therapy services, and
  • Enhancing protection against fraud and abuse by mandating the use of the oxygen template to prevent unwarranted claims denials.

To read more and access resources about the SOAR Act, CLICK HERE.

Enact Common-Sense Policy to Stop Fraud and Abuse

The CQRC supports CMS’s efforts to strengthen fraud prevention and program integrity by:

Adopting a Clear eClinical Template for Prescribers Ordering Supplemental Oxygen. Establishing a clear set of data elements in a template that physicians, not suppliers, complete for use in lieu of physician medical record notes for establishing medical necessity for home oxygen therapies.

Strengthening Supplier Eligibility Requirements for Competitive Bidding. Stopping fraud means taking proactive steps to keep illegitimate organizations from scamming Medicare and beneficiaries. The CQRC recommends CMS adopt the following policies to stop fraud before it starts:

Return to a three-year accreditation cycle and adopt technology-based claims review tools, such as the supplemental oxygen clinical data element template CMS developed but not yet implemented.

  • Reinstate the financial documentation requirements that forced a detailed review of suppliers before they were allowed to bid for Medicare contracts.
  • Requiring CMS and its contractors to review documentation before awarding contracts.

Resources:

  • CQRC infographic Standardize Documentation for Ordering Home Oxygen, CLICK HERE.

Rethinking Medicare’s Competitive Bidding Policies and Testing Reforms

The CQRC commends the Administration for excluding supplemental oxygen and continuous positive airway pressure (CPAP) devices and supplies in the next round of Medicare’s Competitive Bidding Program (CBP) in the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Updates for CY 2026.

The CQRC supports CMS’s efforts to strengthen fraud prevention and program integrity while ensuring policies remain patient-centered and market-based. CQRC looks forward to working with the Administration to ensure Medicare’s proposed Competitive Bidding Program (CPB) methodology does not repeat the failures of previous rounds. Weakening current standards will make the program more vulnerable to fraud and add unnecessary costs while risking beneficiary access to care.

The CQRC recommends CMS:

  • Reinstate the original fee schedule as the benchmark for savings, consistent with statute.
  • Pilot-test alternative methodologies (e.g., capacity-weighted bids, higher percentile thresholds, exclusion of implausibly low bids).
  • Require suppliers to be paid their actual bid amount to discourage strategic underbidding.
  • Maintain strong documentation and review safeguards, use targeted, technology-based approaches.
  • Permanently remove supplemental oxygen from future CBP rounds, establish a new, cost-based reimbursement rate for liquid oxygen, and rebuild Medicare’s supplemental oxygen infrastructure to ensure beneficiaries receive prescribed therapies.

Resources:

  • CQRC’s statement on the CY 2026 Medicare DMEPOS Competitive Bidding Program final rule, CLICK HERE.
  • CQRC’s comment letter to CMS on the proposed Competitive Bidding Program rule, CLICK HERE.
  • Summary of CQRC’s recommendations on the CBP, CLICK HERE.

Secure a Clear Glidepath to New NIV NCD Policies

In 2025, CMS finalized a National Coverage Determination (NCD) for Noninvasive Positive Pressure Ventilation (NIPPV) in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD. CQRC has asked CMS to provide an implementation glidepath of at least 12 months to allow for time for equipment updates to support usage documentation and educate physicians prescribing this therapy without creating barriers to patient care.

Resources:

  • CQRC’s letter to CMS encouraging an implementation glidepath of at least 12 months, CLICK HERE.
  • Stakeholder request to CMS to establish a clear implementation timeline for the NCD for NIPPV, CLICK HERE.

Promote a Long-Term Vision for Home Respiratory Care

The CQRC believes policies to improve patient outcomes and quality of life should be considered by CMS and Congress, including maintaining telehealth policies related to home respiratory therapies, working with the industry to address exponential cost increases resulting from workforce shortages and supply chain issues, establishing a respiratory therapist payment system to fairly reimburse professionals not currently paid under the Medicare program, and working with Congress and stakeholders to address alternative payment models that may be considered for home respiratory therapy.