Clarity on Billing Oxygen Claims During the COVID-19 PHE

Since the COVID-19 Public Health Emergency (PHE) began, the Centers for Medicare & Medicaid Services (CMS) temporarily suspended clinical indication of the Local Coverage Determinations (LCDs) and certain in-person encounters. The CMS’s policy suspensions will stay in place throughout the COVID-19 PHE. Learn more about these changes here.

During this time, the Medbill team has received questions asking for clarification for Medicare orders. The information below should help provide you clarity on the billing guidelines.

Billing Oxygen Claims During the PHE

Since the pause on LCD clinical indications, the Medbill team has received questions asking for clarification for Medicare orders. Below are the guidelines to keep in mind when billing oxygen claims. 

#1 CR Modifier and “COVID-19” Claim Note

Use the CR modifier and “COVID-19” item claim note any time you don’t meet all standard requirements due to the PHE. Use this note whether or not the patient has a COVID-19 diagnosis.

#2 Documentation Requirements 

While there are many flexibilities already in place when it comes to the COVID-19 diagnosis, you still need to make sure you meet the documentation requirements. 


  • Medical records should reflect the need for oxygen
  • Provide a completed Standard Written Order (SWO) 
  • Valid Proof of Delivery

#3 Additional Reminders

  • Once the COVID-19 PHE ends, the DME MACs will return to enforcement of the clinical indications for coverage. 
  • If you need more information on billing claims during the COVID-19 PHE, read more here.

Other Clinical Indications for Coverage 

CMS is not enforcing clinical coverage criteria for claims with dates of service on or after March 1, 2020 (and for the duration of this COVID-19 PHE) in the following NCDs and LCDs.

  • Continuous Positive Airway Pressure for Obstructive Sleep Apnea (NCD 240.4)
  • Durable Medical Equipment Reference List (NCD 280.1) – Only clinical indications for ventilators are not enforced
  • External Infusion Pumps (L33794)
  • Glucose Monitors (L33822) – Only clinical indications for Therapeutic Continuous
    • Glucose Monitors (CGM) are not enforced
  • High-Frequency Chest Wall Oscillation (L33785)
  • Home Oxygen (NCD 240.2)
  • Infusion Pumps (NCD 280.14)
  • Intrapulmonary Percussive Ventilator (NCD 240.5)
  • Mechanical In-exsufflation Devices (L33795)
  • Nebulizers (L33370)
  • Oral Appliances for the Treatment of Obstructive Sleep Apnea (L33611)
  • Oxygen and Oxygen Equipment (L33797)
  • Positive Airway Pressure Devices for the Treatment of Obstructive Sleep Apnea (L33718)
  • Respiratory Assist Devices (L33800)
  • Suction Pumps (L33612) – Only clinical indications for respiratory suction pumps
    • (E0600) are not enforced

Claims – CR Modifier, KX Modifier, Claim Narrative

As a reminder, make sure when you submit a claim with the CR modifier to include the KX modifier or the claim narrative.

For more information on modifiers and claim narrative, click here

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