Last week’s extension of the COVID-19 public health emergency (PHE) continues the relaxed clinical enforcement items CMS outlined in a series of interim final rules (IFR) earlier this year. And while suppliers quickly adapted to provide care in a socially-distanced world, many remain uneasy on how to document patients’ medical need using the relaxed standards.
Existing documentation does not distinguish between baseline medical necessity and permissible deficiencies. We at MiraVista have done our best, based on our experience interpreting CMS guidance and policy, to mold the rudimentary guidelines into more tangible concepts and concrete examples. CMS and the DME MACs continue to issue guidance, and future clarifications may alter our conclusions.
After wrestling with the authoritative publications and various exchanges with Medicare, we boiled it down to this:
Medicare will reimburse services during the public health emergency when medical records meet the spirit of longstanding policies, even if the records do not meet every detail.
CMS is not waiving long standing policy to allow every patient to access services regardless of need. Instead, the CMS instructions temporarily relax some of the formal documentation requirements. The medical records still must demonstrate a baseline medical need for the equipment or supplies as a condition of Medicare payment.
For those that attended our last (K)notes event in June, we covered an array of respiratory products. Here, we revisit oxygen as an example.
Oxygen Baseline
The baseline for oxygen therapy starts with documented hypoxia-related symptoms that might improve with oxygen therapy. Ideally, an objective SAT or ABG test result is available.
Physicians who cannot see patients in person should obtain objective evidence of hypoxia using:
Potentially Permissible Deficiencies for Oxygen Setups
Under the relaxed guidelines, medical records may contain permissible deficiencies where the notes do not contain evidence of:
https://www.phe.gov/emergency/news/healthactions/phe/Pages/covid19-23June2020.aspx
https://cgsmedicare.com/jc/pubs/news/2020/05/cope17333.html
https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf
https://www.govinfo.gov/content/pkg/FR-2020-05-08/pdf/2020-09608.pdf
Existing documentation does not distinguish between baseline medical necessity and permissible deficiencies. We at MiraVista have done our best, based on our experience interpreting CMS guidance and policy, to mold the rudimentary guidelines into more tangible concepts and concrete examples. CMS and the DME MACs continue to issue guidance, and future clarifications may alter our conclusions.
After wrestling with the authoritative publications and various exchanges with Medicare, we boiled it down to this:
Medicare will reimburse services during the public health emergency when medical records meet the spirit of longstanding policies, even if the records do not meet every detail.
CMS is not waiving long standing policy to allow every patient to access services regardless of need. Instead, the CMS instructions temporarily relax some of the formal documentation requirements. The medical records still must demonstrate a baseline medical need for the equipment or supplies as a condition of Medicare payment.
For those that attended our last (K)notes event in June, we covered an array of respiratory products. Here, we revisit oxygen as an example.
Oxygen Baseline
The baseline for oxygen therapy starts with documented hypoxia-related symptoms that might improve with oxygen therapy. Ideally, an objective SAT or ABG test result is available.
Physicians who cannot see patients in person should obtain objective evidence of hypoxia using:
- Telehealth,
- Remote monitoring technology, or
- Overnight oximetry.
- Confusion.
- Shortness of breath or increased respiratory rate.
- Sweating.
- Wheezing.
- Anxiety or restlessness.
- Bluing fingernails or lips.
- Flaring nostrils.
Potentially Permissible Deficiencies for Oxygen Setups
Under the relaxed guidelines, medical records may contain permissible deficiencies where the notes do not contain evidence of:
- Oximetry test results taken while the beneficiary is in a chronic stable state,
- Long-term chronic conditions, or
- Evidence of alternative treatments.
- Discontinue billing if the underlying condition improves, or
- For sustained conditions, obtain objective evidence as soon as it is accessible (before the PHE ends).
https://www.phe.gov/emergency/news/healthactions/phe/Pages/covid19-23June2020.aspx
https://cgsmedicare.com/jc/pubs/news/2020/05/cope17333.html
https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf
https://www.govinfo.gov/content/pkg/FR-2020-05-08/pdf/2020-09608.pdf
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