The Center for Medicare and Medicaid Services (CMS) recently issued a reminder regarding the Oxygen and Oxygen Equipment Local Coverage Determination (LCD) (L33797). This determination mandates that “the treating practitioner has … evaluated the results of a qualifying blood gas study performed at the time of need.” This stipulation means that the physician must have conducted the blood gas study, or if they did not, they need to have personally evaluated the results.
To assist our clients in adhering to this requirement, we want to highlight the most crucial element: documentation. It is essential to ensure that the blood gas study results are included in the patient’s medical records. If the treating practitioner did not perform the study, the results or reference to the evaluation must still be documented. This documentation should indicate that the treating practitioner reviewed the study. While Medicare has now suggested that the test results can be added to the Standard Written Order (SWO) as proof the practitioner evaluated the results, we are urging our suppliers to use extreme caution with this option. If utilizing the SWO as proof the practitioner evaluated the blood gas study, it is imperative to ensure that the test results are documented elsewhere in the patient’s medical records. The documentation must be completed by a qualified medical provider or whoever performed the study, with all records being thorough and clearly stating the involvement of the treating practitioner.
Failure to properly document the blood gas study and the treating practitioner’s evaluation can result in significant issues for suppliers and providers. Incomplete or missing documentation will likely lead to claim denials, while insufficient documentation will cause payment delays, affecting cash flow and operational efficiency.
To ensure compliance, it is crucial to regularly review and update documentation procedures to align with CMS requirements. Educating all relevant staff members on the importance of proper documentation and the specific requirements of LCD L33797 is essential. Conducting regular internal audits will help ensure that all medical records include the necessary blood gas study documentation.
By adhering to these practices, our clients can avoid claim denials and payment delays, ensuring smooth and efficient operations and reducing unnecessary costs. For more detailed guidance and support, please contact the Prochant team.
