WASHINGTON, D.C. – On July 3, 2023, the Centers for Medicare and Medicaid Services published the Calendar Year 2025 Home Health Payment Proposed Rule (CMS-1803-P). While the proposed rule primarily addresses home health agencies, it also includes proposals that could affect DMEPOS suppliers.
The proposed rule introduces a Provisional Period of Enhanced Oversight (PPEO) for providers and suppliers that have their numbers reactivated. This measure aims to ensure that entities re-entering the Medicare program continue to comply with enrollment requirements. Under the proposal, reactivating providers and suppliers will be subject to the same oversight as new participants, which may include prepayment review and payment caps.
In addition, CMS proposed updating the payment rate for Medicare Home Intravenous Immune Globulin (IVIG) items and services next year. Under the Consolidated Appropriations Act of 2023, CMS established a separate payment specifically for administration-related items and services necessary for home IVIG therapy for patients with primary immune deficiency disease (PIDD). CMS proposed to update administration related items and services for IVIG to $430.99, a 2.5% increase from the previous year’s rate.
CMS is accepting comments on the proposed rule through August 26, 2024. You can view the Federal Register publication and submit comments here. See AAHomecare’s proposed rule summary for additional perspective.
Clarification on Blood Gas Test Documentation Requirements
WASHINGTON, D.C. – Last week, the Durable Medical Equipment Medicare Administrative Contractors (DME MACs) published clarifications regarding the documentation requirements for blood gas test results, as outlined in the Oxygen and Oxygen Equipment Local Coverage Determination (L33797). This guidance directly impacts how treating practitioners must document and evaluate blood gas study results for patients requiring oxygen therapy.
When a treating practitioner directly conducts the qualifying blood gas study, their documentation of the results fulfills both the requirement to include the study results in the medical record and the requirement for the practitioner to evaluate the results. However, if the treating practitioner does not directly conduct the blood gas study, additional documentation is needed to show that the treating practitioner reviewed the results. Below are some acceptable examples of such documentation provided by the DME MACs in last week’s clarification notice:
- The incorporation of a copy of the blood gas study or the results from the blood gas study into the treating practitioner’s chart notes; or,
- Treating practitioner documentation in which he/she references the evaluation of the blood gas study performed on a specific date; or,
- The treating practitioner’s signature on a copy of the blood gas study results. The treating practitioner’s signature indicates he/she evaluated the results; or,
- Inclusion of either of the following on the treating practitioner’s standard written order (SWO) for home oxygen therapy: blood gas study results or reference to the evaluation of the blood gas study performed on a specific date.
- Note: While inclusion, of either of the above, on the treating practitioner’s SWO may support that the treating practitioner evaluated the blood gas study results, as previously noted the results of the blood gas study must also be documented in the medical record documentation rendered by a practitioner, qualified provider, or supplier of laboratory services who performed the study.
This clarification comes in response to requests from the supplier community seeking more precise guidance.