There is no end in sight for providers concerned about the Centers for Medicare and Medicaid Services (CMS) proposal to increase the recertification requirements for some patients on home oxygen therapy. Although the open comment period for the proposal—which would change the certification requirements for Group I oxygen patients to match those of Group II patients—has ended, CMS and DME Regional Carrier (DMERC) representatives note that there is no deadline attached to releasing the final policy.

Of primary concern to suppliers is that, under the new requirements, chronically ill Group I oxygen patients may be needlessly retested, further taxing already limited testing resources and complicating reimbursement for oxygen and its related services. Currently, those patients who qualify as Group II must undergo retesting between the 61st and 90th day after implementation of home oxygen therapy. For the patient who qualifies for the Group I category, there is no retesting requirement at this time. However, under the draft policy guidelines, all patients on home oxygen therapy would require retesting within the 61st to 90th day period.

Facing the Testing Shortage
Obtaining test results to qualify patients for home oxygen therapy may represent the biggest challenge HME providers face. Take the case of Paula Bastiaanse of Baycair Home Respiratory Services in Halethorpe, Md. In her area there is only one testing laboratory and, according to Bastiaanse, it does little to accommodate her clients’ schedules.

“It is open only until 3 pm weekdays, with no evening or weekend hours available,” she says. “Our test dates out are a minimum of 30 days, with some patients still waiting to be tested 85 to 90 days out, and there are frequent cancellations.”

The Western states fare no better. Janet (Penny) Peterson, owner of Peterson Oximetry Services in Lehi, Utah, notes that the Southern California area is 3 to 4 months out in getting testing done.

“One of the primary problems in getting the patients tested is access,” says Jacki McClure, director of the MED Respiratory Network for The MED Group, Lubbock, Tex. “Reductions in allowables to the Current Procedure Terminology (CPT) fee schedule have eliminated competitiveness. There are about 1,400 Independent Diagnostic Testing Facilities (IDTFs) across the country and only 46 perform oximetry testing. That certainly limits access.”

Peterson agrees. “When reimbursement dropped 30%, it was no longer financially feasible to send a technician 50 to 100 miles to perform an oximetry test, so we became proactive,” she says.

Legal Options
Determined to find an alternative way to meet patient needs, Peterson began communicating with Robert Hoover, MD, medical director for the Region D DMERC, in December 2001. She asked Hoover if a technician from an IDTF could perform oximetry testing on the physical premises of a DME supplier and if an IDTF, in order to perform overnight oximetry testing, could provide a sealed oximeter to a DME company for delivery and pickup by the DME company. She noted that, in these circumstances, all test results would be downloaded and faxed to the treating physician by the IDTF. Hoover responded positively, noting that both were permissible “predicated on the assumption that there are no payments or other remuneration between the IDTF and the DME company as part of the arrangement.”

The same response came from the Region B DMERC in the Region B Council Questions and Answers in February 2002. Region B stated that “it is permissible for a technician from an IDTF to perform oximetry testing on the physical premises of a DME supplier, if the tests are downloaded to the IDTF and faxed by the IDTF to the ordering physician.”

Could on-site testing performed at the physical location of the DME supplier reduce or eliminate testing delays? Yes, says Peterson.

“Our goal for the near future is to have a testing time regularly set up at the DME office, where patients will come for full testing,” she says. “The DME will have control of when the testing is done and an oximeter for overnight testing will go home with the patient. In addition, on the testing day, sealed oximeters may be supplied so patients who cannot come in can be serviced with overnight testing. After the overnight testing is completed, the oximeters are returned to the DME office in a sealed envelope and then picked up and downloaded by our company.”

It appears to be a win-win situation on all sides, but Peterson has had few takers, perhaps because HME suppliers either are concerned about the legalities of this type of arrangement or are unaware of the concept.

Teach Referral Sources
Another way to help alleviate the testing shortage is to educate referral sources, emphasizes McClure. “Supplier education to the physician should not only include recognition of testing requirements for qualifying the home oxygen patient, but the supplier should provide the CPT codes, fee schedules, testing equipment information, and pricing to the physician so an informed decision can be made,” she says. “Overnight oximetry testing may prove to be profitable for a well-staffed physician practice if the manpower is already available. Then the only additional costs involved, other than the equipment, would be for shipping.”

As an additional step in helping to educate physicians, McClure advocates including the testing requirements for qualifying the patient on the patient plan of care forwarded to the physician.

Testing delays and limited access to testing for a patient who has a need for home oxygen therapy create excessive financial burdens on the DME supplier who starts providing oxygen and related services based on a physician’s order. While waiting for the required testing to be performed to qualify the patient for reimbursement, the patient’s condition may worsen, requiring nursing home care, or the patient may even pass away. In these situations the supplier is unable to bill (often for several months) because there are no test results. The supplier is forced to pick up the equipment and write off the cost of the setup and service provided.

With impending policy changes that may require additional testing, the situation becomes more critical. If the initial qualifying test currently cannot be obtained for several months, how can the supplier hope to obtain additional testing, if it is required for Group I patients between the 61st and 90th day? Until CMS recognizes the discrepancy in reimbursement for the required testing, suppliers must look for timely alternatives and take a proactive stand. Certainly, physician education is a key component of the equation. Perhaps on-site testing at the supplier facility by an IDTF may offer a positive solution.

Helen M. Farrell is a reimbursement consultant and CEO of Medical Accounting and Reimbursement Services (MARS), Chesapeake, Va. Contact MARS at (757) 410-1732.

Respiratory Insider Ensuring patient compliance with continuous positive airway pressure (CPAP) therapy poses a major challenge and opportunity for providers, according to Ron Richard, vice president of marketing for the Americas at ResMed, Poway, Calif. Dealer/Provider spoke with Richard about why compliance is important and how dealers can promote it. Q How can ensuring CPAP compliance benefit home health care dealers? A Providing patients with the right mix of educational support, products, and follow-up is a challenging, yet rewarding, task in many aspects. Patients communicate their feelings and experiences to their physicians and sleep laboratories, who in turn keep mental notes on the providers who are doing the best work with their referrals. In addition, strong patient relationships can boost recurring business. Dealers who keep in touch with their CPAP patients often are surprised by the amount of revenue that can be generated in terms of replacement supplies, such as masks, headgear, and other routine parts. Of course, starting patients on the right CPAP system—meaning a positive airway pressure machine (CPAP, autoset, or bilevel), humidifier, mask, and tubing—is key to improving compliance and reducing overall costs. Q What kind of compliance-promoting products are available? A Today, masks are much more comfortable and easier to apply to patients than they were in the past. PAP devices are getting smaller and more lightweight, as well as incorporating integrated humidification. With the technology ResMed has built into its latest generation of PAP devices, clinicians can download the information from the units and get a wide range of data with the push of a button, which saves time and resources and removes the guesswork from handling patient complaints. Q It is often a hassle for providers to carry a wide array of different brands of CPAP units. How can ResMed help? A ResMed’s PAP devices share several common components across the product line, including filters, integrated humidifiers, setup instructions, and menu options. This reduces in-service issues at the technician level, reduces inventory and service problems, and promotes a more efficient approach to managing an HME business. In terms of masks, providers want a wide spectrum of interface options as this can be the most important facet of getting the therapy right the first time. ResMed has been a leader in mask technology, and we have very exciting new products coming out this year that will use common parts throughout the product line, further reducing inventory needs. Expect us to make more improvements and raise the bar once again for the industry.