Our physicians and other practitioners who write prescriptions for oxygen supplies and equipment need guidance on Medicare’s documentation requirements. Can you help?


In February 2018, the Centers for Medicare & Medicaid Services (CMS) released a fact sheet called “Provider Compliance Tips for Ordering Oxygen Supplies and Equipment (ICN 909410). It starts out by saying that for the 2017 reporting period, insufficient documentation accounted for 84.9 percent of improper payments for oxygen supplies/equipment, so your plan to educate physicians is a good one.

Within the fact sheet, CMS says that the medical record must contain timely documentation of the beneficiary’s medical condition to support the continued medical necessity of the type and quantity of items ordered and for the frequency of use or replacement. Documentation must include elements such as the following:

  • The physician orders for the oxygen supplies
  • Oxygen saturation results
  • Physician evaluations demonstrating oversight of the beneficiary, the continued medical necessity of oxygen supplies, and the appropriateness of home and/or portable oxygen supplies
  • A properly completed Certificate of Medical Necessity (CMN), signed, completed, and dated by the treating physician using the CMS Form 484, and the supplier must keep a copy and provide it upon request. Medicare will deny claims submitted without a valid CMN and determine they are not medically necessary

This fact sheet can be found by doing a Google search for ICN 909410.


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