Clinicians Ordering Oxygen and Oxygen Equipment - Reference Guide with Information for the COVID-19 Public Health Emergency (PHE)


As a result of the COVID-19 PHE, the Centers for Medicare & Medicaid Services (CMS) has issued waivers and flexibilities to assist Medicare beneficiaries in obtaining the services they need and allowing practitioners to utilize home oxygen therapy when they determine it is warranted.

While the coverage criteria for home oxygen have not changed, CMS-1744-IFC (PDF, 860 KB) and CMS-5531-IFC (PDF, 1.19 MB) have provided direction regarding use of telemedicine in place of face-to-face requirements and non-enforcement of the clinical indications for coverage of home oxygen therapy. CMS has also emphasized that the oxygen must be reasonable and necessary for the condition for which it is being prescribed and that condition must be documented in a medical record.

This documentation may be in the form of a prescription written by the patient’s attending physician who has recently examined the patient (normally within a month of the start of therapy) and must specify:

  • A diagnosis of the disease requiring home use of oxygen;
  • The oxygen flow rate; and
  • An estimate of the frequency, duration of use (e.g., 2 liters per minute, 10 minutes per hour, 12 hours per day), and duration of need (e.g., 6 months or lifetime)

A prescription for “Oxygen PRN” or “Oxygen as needed” does not meet this last requirement. Neither provides any basis for determining if the amount of oxygen is reasonable and necessary for the patient.

It is important to note that the National Coverage Determination (NCD) for oxygen, along with the Local Coverage Determination (LCD) and Policy Article (PA) have not changed. The only allowance during the COVID-19 PHE is that the clinical indications of coverage will not be enforced. When the PHE ends, these requirements will resume.

For additional information, please visit the appropriate DMEPOS website and view their information on COVID-19.

  • Jurisdiction A (Conn., Del., Mass., Maine, Md., N.H., N.Y., Pa., R.I., Vt., District of Columbia)
  • Jurisdiction B (Ill., Ind., Ky., Mich., Minn., Ohio, Wis.)
  • Jurisdiction C (Ala., Ark., Colo., Fla., Ga., La., Miss., N.M., N.C., Okla., S.C., Tenn., Texas, Va., W.V, Puerto Rico, U.S. Virgin Islands)
  • Jurisdiction D (Alaska, Ariz., Calif., Hawaii, Idaho, Iowa, Kansas, Mo., Mont., Neb., Nev., N.D., Ore., S.D., Utah, Wash., Wyo., American Samoa, Guam, Northern Mariana Islands)




Last Updated: 11/24/2020