Supplemental Oxygen Reform
Congressional Action Needed to Address Access to Supplemental Oxygen Background
- Supplemental oxygen is a statutorily covered service under the Durable Medical Equipment benefit for Medicare beneficiaries who show clinically relevant oxygen desaturation levels at rest or during exercise.
- There are several different modalities for the delivery of supplemental oxygen, each with its own strengths and limitations.
- Since the implementation of the competitive bidding program, claims for all oxygen modalities have dropped dramatically, with liquid oxygen seeing the most significant drop. Liquid oxygen is an important modality for patients who need high oxygen flow rates. o Liquid stationary between 2017 and 2021 went from 62,371 claims to 16,716 – a 73% decline
- Liquid portable went from 95,859 to 24,942 claims during the same timeframe – a 74% decline
- There have been no changes to respiratory disease patterns that would explain the sharp decrease.
CMS and Congress Recognize Problems with Liquid Oxygen
- In 2019, CMS made modest payment changes for liquid oxygen by establishing new payment classes.
- Bipartisan Congressional letters to CMS identified concerns regarding declining access to supplemental oxygen, particularly in rural areas, and called for them to act.
- For FY 2021, the House appropriations bill included report language expressing continued concern over lack of access for liquid oxygen. o It requested CMS to report to Congress within 60 days on current access and trends in use between 2010 and 2019.
- CMS acknowledged there are access issues and is monitoring the effect of its earlier revisions to payment rates noted above.
COVID-19 Exacerbated the Problem
- Challenges around access to supplemental oxygen have prevented Medicare beneficiaries from getting needed equipment post-hospital discharge. o Hospital discharges have been delayed due to lack of available supplemental oxygen,
- Regional shortages of oxygen have negatively impacted those recovering from COVID- 19 and patients with other health conditions who need this critical treatment.
Congress Must Pass Comprehensive Oxygen Reform
- The pulmonary community urges Congress to fix well-documented problems with access to supplemental oxygen.
- Needed reforms include:
- Creating a statutory service element to provide adequate reimbursement for respiratory therapists to ensure patients have access to their expertise.
- Ensuring supplemental oxygen is patient-centric by moving away from “home” oxygen to “supplemental oxygen” and creating a patients’ bill of rights.
- Ensuring access to liquid oxygen for patients for whom it is medically necessary.
- Establishing national standardized documentation requirements that rely upon a template rather than prescriber medical records to support claims for supplemental oxygen suppliers to ensure predictable and adequate reimbursement and to protect against fraud and abuse