The American Association for Homecare and VGM & Associates joined several respiratory groups in sending a letter to HHS Secretary Xavier Becerra calling for CMS to outline a post-PHE policy that will protect respiratory patients.
“With the recent announcement that the Covid-19 Public Health Emergency will end on May 11, we request that the Centers for Medicare & Medicaid Services provide a clear transition policy for Medicare beneficiaries who rely upon supplemental oxygen and respiratory therapies, including sleep therapies and non-invasive ventilation to remain in their homes and their communities,” the letter reads.
AAHomecare and VGM joined The American Association for Respiratory Care, American Lung Association, American Thoracic Society, Council for Quality Respiratory Care and Pulmonary Fibrosis Foundation in signing the letter, which is available as a PDF.
Some key transition policy objectives the letter urged CMS to adopt include:
- CMS should grandfather patients receiving home oxygen, sleep therapy, or non-invasive ventilation equipment in terms of the qualification requirements that were in place during the pandemic.
- Ensure that any patient set up during the PHE who ended service and had their equipment picked up during PHE will not have his or her claims subject to a medical necessity audit.
- CMS should remove the medical record review and accept the clinician prescription/standard written order as the required documentation for establishing medical necessity, as it does for other prescription medications.
Additionally, the letter urged CMS to adopt the clinical data element (CDE) oxygen template as the required documentation for establishing medical necessity for beneficiaries receiving supplemental oxygen.
“CMS has created a set of CDE templates that could quickly be updated to address the new policies under the revised oxygen NCD,” the letter notes. “Requiring Medicare contractors to recognize this document as the basis for medical necessity is long overdue.”