January 31, 2025, marks the fifth anniversary of the COVID-19 public health emergency (PHE). This milestone highlights the lasting impact of the pandemic on healthcare and equipment management. Many devices put into use during the PHE are now reaching the end of their reasonable useful lifetime (RUL), making it essential to assess replacement strategies and long-term readiness. Oxygen suppliers are almost certainly wondering,
“Does Medicare require a new qualifying blood gas study and chart notes to provide replacement equipment?”
In short, Medicare does not require requalification under the normal coverage rules if the supplier:
- Set up the initial oxygen equipment between March 1, 2020, and May 11, 2023,
- Relied on PHE clinical waivers to qualify the patient, and
- Included the CR modifier and COVID-19 narrative on billed claims.
And – bonus – unlike many other product categories, Medicare will replace oxygen equipment at the end of its five-year RUL even if the original device is still functioning.
To qualify oxygen patients for replacement equipment, suppliers must:
- Document continued use,
- Obtain a new order from the patient’s physician to establish current medical need,
- Add the RA modifier and applicable narrative to the claim for the first month’s replacement, and
- Continue to use the CR modifier and COVID-19 narrative on claims for replacement equipment.
Ultimately, the clinical waivers that permitted patients to qualify for oxygen during the PHE carry over to new equipment if the device remained in continuous use from original setup. In those cases, suppliers do not need to obtain chart notes and test results that support coverage under the normal guidelines.
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