08/06/2021

AAHomecare Shares Comments on CMS Home Oxygen NCD Memo

AAHomecare submitted comments on CMS’ Proposed Decision Memo for Home Use of Oxygen and Home Use to Treat Cluster Headaches.  As they noted in their July 7 AAH Insider, the Association provided comments on last year’s opening of the National Coverage Analysis on the issue and was one of 12 organizations referenced in the proposed memo; a majority of their previous recommendations are reflected in the memo.

AAHomecare’s comments express their full support for CMS’ proposal to expand coverage of home oxygen therapy to beneficiaries with acute and chronic conditions, for short- and long-term therapy.  Other issues covered in our comments include:

• Support for removal of CMN requirement as long as home oxygen CDEs are made mandatory.
• Ensuring clear and objective medical need documentation.
• Clarifying pulse oximetry requirements.
• Eliminating references to portable oxygen.

AAHomecare’s complete comments can be found here.