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.
Frequently Asked Questions
Do PHE oxygen patients need to requalify for Medicare replacement equipment?
Under the circumstances described in the article, normal requalification is not required when the original oxygen setup occurred between March 1, 2020, and May 11, 2023, the patient qualified under PHE clinical waivers, and the supplier billed with the CR modifier and COVID-19 narrative. The equipment must also have remained in continuous use.
What documentation is needed to replace oxygen equipment after its five-year useful lifetime?
The supplier should document the patient’s continued use and obtain a new physician order establishing current medical need. For the first month of the replacement, the claim should include the RA modifier and applicable narrative. Replacement claims should also continue using the CR modifier and COVID-19 narrative associated with the original PHE qualification.
Will Medicare replace oxygen equipment that still works after five years?
The article states that Medicare will replace oxygen equipment at the end of its five-year reasonable useful lifetime even when the original device still functions. For eligible PHE patients whose equipment remained in continuous use, the earlier clinical waiver carries over, so the supplier does not need new chart notes and test results supporting normal qualification.
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