Oxygen documentation needs (ACA, Face to Face visit is required)

The following qualification criteria need to be documented in the patients’ medical record notes to qualify for the prescribed equipment. Note: Face to face and justification notes are valid for 30 days.

All of the following need to be sufficiently documented to support the need for the prescribed equipment.

  • Explain the patient’s severe lung disease or hypoxia-related symptoms that might be expected to improve with oxygen therapy
  • Document the patient’s required blood gas or arterial saturation(s).
  1. Saturation on Room air at rest. Note: If 88% or below no other testing is needed
  2. Saturation during exercise without oxygen.
  3. Saturation on oxygen with ambulation.
  4. Nocturnal oximetry saturation.
  5. Date the test was performed


-Exercise testing - a, b, c must be completed and taken in the correct order and completed in the same session. The testing session must be supervised by qualified personnel at a hospital, clinic or facility.

-Oxygen 4LPM and above- The patient must be tested while on 4 liters of oxygen or more.

-Obstructive Sleep Apnea (OSA) and oxygen- The patients OSA must be treated before dispensing oxygen.

-Inpatient sat levels are valid for 2 days, outpatient sat levels are valid for 30 days. 

  • Explain what alternative treatment measures have been tried or considered and deemed clinically ineffective. Example: Nebulizer compressor, medication, Cardio rehab, etc.
  • Explain if the patient is mobile within the home. Note: Must be documented for portable oxygen. 

Diagnosis: See LCD (Local coverage determination) at CGSMedicare.com for any additional qualifying information questions, diagnosis codes and descriptions.

Medicare-approved detailed equipment descriptions for Oxygen

Concentrator, stationary system, (HCPC-E1390)
Portable concentrator (HCPC-E1392)
Portable gas system and gaseous oxygen content, (HCPC-E0431)
Portable gas oxygen system, home fill unit, (HCPC-K0738)


Patient notes/justification – Must be documented using your normal dictation process. Letter of medical necessity, notes wrote on letterhead or prescriptions are not valid.

Prescription/order requirements– Must contain Patient’s name, date of the order and Start date, detailed equipment description (See above), Physician’s NPI (national provider number), signature of the ordering physician and a signature date.