Proposed O2 Changes Include Industry Input

CMS’s proposed changes to oxygen National Coverage Determination incorporate many recommendations made by AAHomecare.

The changes to the Oxygen National Coverage Determination (NCD) that CMS proposed last week reflect several recommendations proposed by the American Association for Homecare that would expand oxygen coverage and ease supplier burdens.

In “Proposed Decision Memo for Home Use of Oxygen and Home Oxygen Use to Treat Cluster Headaches (CAG-00296R2),” stated it had received 200 comments during the August-September 2020 comment period for the National Coverage Analysis (NCA) for Home Use of Oxygen Use to Treat Cluster Headaches.

Of those comments, AAHomecare reports 12 recommended changes to the NCD for Home Use of Oxygen incorporate a majority of the association’s recommendations. The changes would expand oxygen coverage for patients and reduce paperwork burden for suppliers.

AAHomecare extracted the salient provisions for home oxygen providers:

  • Removal of the Certificate of Medical Necessity (CMN) requirement. CMS recognizes that the CMN form is no longer needed for claim processing purposes or medical reviews.
  • Recognition that there are limitations with using a pulse oximeter to determine blood oxygen levels. It can be useful in estimating blood oxygen levels, but it is not effective in measuring the exact level.
  • Expansion of coverage for acute condition and removes references to ‘chronic stable state’.CMS proposes initial coverage be limited to 90 days or less for situations unrelated to hypoxemia. Oxygen coverage can be renewed within 60-90 days if there is continued need.
  • Removal of the trial of alternative therapies prior to oxygen coverage. CMS states it believes it is the treating practitioner’s responsibility to determine whether oxygen therapy is reasonable and necessary.
  • Recognition that oxygen therapy is not only needed for lung diseases. The NCD discusses ability to breath as a primary driver, not desaturation. 
  • Discretion for DME MACs to determine whether oxygen coverage is reasonable and necessary. However, the NCD is clear that oxygen coverage is available for all patients that need it. 

CMS is accepting public comments on the proposed changes until Aug. 1 and will publish a finalized Oxygen NCD after it reviews the comments on Sept. 30. The finalized NCD will be effective the day it is published, and the new NCD will supersede the Local Coverage Determinations (LCDs). 

“AAHomecare’s Regulatory Council convened [Tuesday] to review and develop comments to the proposed changes,” a statement from the association read.

To comment, click the orange “comment” button at the top of CMS’s memo.

About the Author

David Kopf is the Publisher HME Business, DME Pharmacy and Mobility Management magazines. He was Executive Editor of HME Business and DME Pharmacy from 2008 to 2023. Follow him on LinkedIn at and on Twitter at @postacutenews.

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