Funding Focus: Perplexing to Providers
Travel Oxygen Programs
- By Kelly Riley
- Oct 01, 2009
Recently, it became mandatory for the Federal Aviation
Administration (FAA) and hence, all airlines, to comply with
new rules that make for friendlier skies for patients requiring
oxygen while in flight. The ruling, passed by the U.S. Department of
Transportation (DOT) with an effective date of May 2009, requires
airlines to accommodate patients who travel with pre-approved
portable oxygen concentrators (POCs). Although the ruling now
helps oxygen patients move more freely about the country, the
same cannot be said for the suppliers who provide the oxygen and
services upon which these patients rely.
During the same month that the DOT ruling went into effect,
CMS (via the DME/MACs) posted a transmittal directing providers
on how to manage Medicare beneficiaries who travel outside
their suppliers’ service areas. The transmittal went so far as to
include a “back dated” effective date of January 2009. This was
done, CMS explained, to reflect changes due to the MIPPA enactment
published in July 2008 with an implementation date of
January 2009 for many of its components. The CMS transmittal
states in part:
A new payment policy for oxygen became effective on January 1,
2009. This article addresses issues related to short-term travel
(e.g., days or weeks) or to temporary relocation (e.g., snowbird)
outside of the supplier’s service area.
In this article, the term “oxygen” includes the equipment,
contents (if applicable), and all related items and services
including, but not limited to accessories, maintenance, and
The transmittal outlines a provider’s responsibilities based on
when in the reimbursement cycle the equipment is being billed.
It is divided into provider responsibility during months 1 through
36, and post-36, of Medicare reimbursement. Providers have
known for several months the burden they must carry after they
receive the final payment at the 36th month. However, this
transmittal, as well as other documents released since its issue,
has caused quite a stir. The provider responsibility for months 1
through 36 of rental service that is implied by the transmittal
indicates that once again, providers have been dealt a blow.
The policy specifies that for those pre cap months the
supplier must abide by the following requirements:
- If the beneficiary travels or relocates outside the supplier’s
service area, then for the remainder of the rental month for
which it billed, the home supplier is required to provide the
oxygen itself or arrange for a temporary supplier (non-billing)
to provide the oxygen.
- For subsequent rental months that the beneficiary is outside
the service area, the home supplier is encouraged to either
provide or arrange for the oxygen itself or assist the beneficiary
in finding a temporary supplier (billing) in the new location.
- If the home supplier provides oxygen to the patient for use
out-of-area or arranges for a temporary supplier (non-billing)
to provide the oxygen, the home supplier bills for whatever
system the patient is using on the anniversary date/billing
date. The supplier may provide the patient with different
oxygen equipment (e.g., portable concentrator) for travel, if
there is an order from the physician.
- The home supplier may not bill for or be reimbursed by
Medicare if it is not providing oxygen or has not arranged for a
temporary supplier (non-billing) to provide the oxygen on the
anniversary billing date.
Most providers want to support and encourage their patients
to maintain active lives, and that often
includes travel. However, facilitating
travel (especially outside of the
supplier’s service area) can be daunting
for the provider, both in terms of staff
time required to make arrangements as
well as added cost for actual product.
Current reimbursement by CMS for
patients who are ordered to have oxygen
provided for ambulation averages a mere
$25 to $50, depending on the technology
they receive. That amount is quickly
depleted, whether by providing cylinders
or advanced technology (either a
portable oxygen concentrator such as a
SeQual, or a transfilling device such as I-fill). Whenever patients
travel, company resources are required to:
- Gather and copy or send via fax documents the patient will need
- Ship additional equipment
- Facilitate numerous calls to arrange for another provider
willing to provide backup emergency services should equipment
Many of these processes are required regardless of the size of
the HME Company.
“Facilitating travel can be daunting for
the provider, both in terms of staff time
required to make arrangements as well
as added cost for actual product.”
Where We Stand
There is currently an ongoing effort to clarify at least, and eliminate
at best, this latest blow to respiratory providers. The
American Association for Homecare (AAHC), with input from the
associations’ regulatory council, recently sent a letter to the
DME/ MAC medical directors and to CMS. The letter states that
the policy on travel oxygen imposes an unworkable obligation
upon providers, who have no influence or control over beneficiary
travel decisions. It further states that the policy represents
a significant departure from a longstanding body of policy that
holds Medicare beneficiaries responsible for arranging for their
oxygen when they travel away from home. The policy is also
inconsistent with well-established rules that control billing for
“same or similar equipment,” which Medicare does not cover.
As of this writing, the medical directors have responded to
AAHC’s letter, and deferred the issue to CMS.
Until this matter is resolved, providers are encouraged to
concisely document all conversations with beneficiaries
regarding travel, and solidify company policy on this, which
includes communicating the policy clearly to all staff.
Given this latest, it remains imperative that all oxygen
providers continue to contact their State representatives to garner
support for oxygen reform. Removal of the oxygen payment cap
would make life easier for patients and providers alike.
This article originally appeared in the Respiratory Management October 2009 issue of HME Business.
About the Author
Kelly Riley, CRT, is director of The MED Group's National Respiratory Network and has more than 25 years of experience in the respiratory arena.