Not long ago, the primary challenge for HME companies
in providing maintenance and service on
oxygen equipment was simply catching up with the
patient. I recall seeing open orders for routine maintenance
stay on the list for months as patients dragged their
feet in setting up appointments with our technicians or
were not home when the technicians arrived at the scheduled
time. (Too many times due to an emergency trip to
the casino or to play canasta!)
As of July 1, 2010, maintenance and service became
even more complicated. On Oct. 30, 2009, CMS issued a
final rule extending maintenance and service reimbursements
through June 30, 2010, under the same methodology
as 2009. However, the agency changed the protocol
for maintenance and service rendered after July 1, 2010.
Here are highlights of the change:
- The payment amount is fixed at $66.
- Not only must the supplier physically visit the home of
the beneficiary (no change from 2009), the visit must take
place during the first month of the six-month period. - A supplier is not required to visit. However, should he
choose not to, he is required to ensure that the equipment
is still in working order, that the beneficiary has
not requested the equipment be checked, and that he
does not bill for maintenance and service. - The applicable date of service must be at least six months
after the 36-month rental cap for oxygen equipment or
the end of the warranty period for maintenance and
service, whichever is later. Further, before a supplier
can bill for maintenance and service, the supplier must
verify and document in the records that the oxygen
equipment is no longer covered under a warranty. - The rule applies to the following oxygen concentrator
and oxygen transfilling equipment HCPCS codes:
E1390: Oxygen concentrator
E1391: Oxygen concentrator, dual delivery port
E1392: Portable oxygen concentrator, rental
E0433: Portable liquid oxygen system, rental
K0738: Portable gaseous oxygen system - The rule does not apply to beneficiary-owned oxygen
equipment or to the following liquid and gaseous oxygen
equipment HCPCS codes: E0424, E0431, E0434 or E0439. - When billing for maintenance of a portable oxygen
concentrator, suppliers must use code E1390 MS, not
E1392 MS. This has caused some confusion because,
during the rental period, suppliers bill for both E1390 and E1392 for the POC. CMS will only make one maintenance
and service payment, regardless of the combination
of equipment provided to the patient.
The second-most burdensome issue for suppliers will
be trying to hit that limited 30-day window to actually
connect with the patient to perform the work. One
solution is to notify patients well in advance about the
restrictive time frame. CMS has communicated that in
unavoidable circumstances, such as the hospitalization
of a patient, an exception can be made. This should be
documented in the patient record as well as noted in the
narrative field. The next maintenance and service visit,
then, cannot occur for another six months, resulting in a
“moving anniversary date.”
However, the biggest problem suppliers will face is
determining if the oxygen equipment patients have in
their possession is still under warranty. Many companies
do not track this within the billing area of their operating
systems, but instead in their technical or warehouse
records, and the data may or may not be computerized.
HME suppliers should question manufactures about
equipment-failure rates in year four and five of use. Most
of us know (or think we do) which manufacturers have
higher failure rates, so choose manufacturers with proven
rates of less than 2.5 percent. But always double check that
against your own data. By doing this, going with a threeyear
warranty instead of five may yield a better ROI.
These issues will have to be addressed if your organization
is going to continue to make service calls, and most
will as it provides an opportunity to ensure the company’s
assets are still where they are reported to be. Also,
it provides an opportunity to bring in some revenue after
the cap kicks in. For example, an HME company with
150 oxygen patients that collects the fee for the about 14
percent of patients who make it to months 36-60 would
gain approximately $4,000 in additional top-line revenue.
In this industry, it is critical to try to recoup our costs
of doing business. Every time CMS changes a policy, it
warrants an evaluation of your company’s processes, too.
Portions of this article are based on the CMS publication
“MLN Matters: Number MM6990.” For more details, check
with your local Medicare Administrative Contractor.
