Documentation for Ordering Oxygen Supplies and Equipment

March 9th, 2018 - Medicare Learning Network
Categories:   Documentation Guidelines   Medicare  

The Medicare Learning Network provides guidance on required documentation for Ordering Oxygen Supplies and Equipment. 

The beneficiary’s 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 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

The detailed written order must include the following:

  • The beneficiary’s name
  • A detailed description of the provided items, including the means of oxygen delivery (e.g., mask, nasal cannula, oxygen flow rates, and the length of need). NOTE: A prescription for “Oxygen PRN” or “Oxygen as needed” does not meet this requirement
  • The treating physician’s dated signature, including the start date of the order (if different from the signature date)

Documentation should include all of the following:

  1. The treating physician has determined that the beneficiary has a severe lung disease or hypoxia-related symptoms that might be expected to improve with oxygen therapy
  2. The beneficiary’s oxygen saturation meets the qualifying criteria (below)
  3. The qualifying oxygen saturation was performed by a physician or by a qualified provider or supplier of laboratory services
  4. The qualifying oxygen saturation was obtained under the following conditions:
    • If the qualifying oxygen saturation is performed during an inpatient hospital stay, the reported test must be the one obtained closest to, but no earlier than 2 days prior to the hospital discharge date
    • If the qualifying oxygen saturation is not performed during an inpatient hospital stay, the reported test must be performed while the beneficiary is in a chronic stable state – that is, not during a period of acute illness or an exacerbation of their underlying disease
  5. Alternative treatment measures have been tried or considered and deemed clinically ineffective

Qualifying criteria for oxygen saturation results:

  • Obtain test results within 48 hours of the date of delivery unless the oxygen saturation tests were taken during an outpatient encounter or during the beneficiary’s sleep. This would require test results within 30 days of the date of delivery
  • Classify test results into Group I or Group II with their respective CMN requirements. See CMS Pub. 100-03, Medicare National Coverage Determinations Manual, Chapter 1, Section 240.2 (B) for Certificate of Medical Necessity – Oxygen requirements


Medicare covers a portable oxygen system if the beneficiary is mobile within the home, and the qualifying blood gas study was taken in one of these three scenarios:

  • While the beneficiary is at rest
  • While he or she is awake
  • During exercise

The treating physician must sign, complete, and date the CMN 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.

Medicare payment for oxygen delivery equipment in the beneficiary’s home is allowed under certain conditions. Medicare pays for oxygen on a capped rental basis for a 36-month period.


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