Updated FAQs address NCDs for home oxygen and face-to-face requirements during the COVID-19 PHE

June 10, 2020
Medicare Web

CMS updated its Medicare billing FAQs to include new questions related to National Coverage Determinations (NCD) during the novel coronavirus (COVID-19) public health emergency (PHE).

The new FAQs are in Section W NCD and address the following:

  • Using telehealth to meet NCD face-to-face requirements.

CMS will not enforce face-to-face requirements included in NCDs, local coverage determinations (LCD), or articles for the duration of the COVID-19 PHE. However, certain durable medical equipment items may have different requirements contained in statutes, regulations, or durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) quality standards that are still enforceable during the PHE.

  • DMEPOS documentation requirements and practitioner signatures.

All DMEPOS documentation requirements remain in effect including those requiring a written order signed by the practitioner. Practitioners may submit electronic signatures.

  • Providing oxygen to patients who can’t be seen by a physician.

Patients who can’t be seen by a physician according to the timeframe required by the LCD may continue to receive oxygen and the supplier may submit a bill for it. CMS expects the medical record to demonstrate that the services were medically necessary, actually provided, and provided at the level billed.

  • Coverage for home oxygen.

CMS will not be enforcing NCD 240.2, which requires that certain health conditions be met for home oxygen to be covered, for the duration of the PHE. The medical record should support that home oxygen was medically necessary and was provided and billed at the appropriate level.


Other new FAQs in Section W address face-to-face encounter requirements for power-mobility devices and prosthetics, requirements for coverage of end of life care in the patient’s home, and more.