Guest Post by Helen Gelly, MD: Hyperbaric Oxygen Therapy Charges About To Be Stretched On the RAC

Special Guest Blogger- Helen Gelly, MD

Since 2014, when CMS started the process of implementing the Prior Authorization of Non-Emergent Hyperbaric Oxygen, hyperbaric therapy has been firmly between the crosshairs of CMS.

https://carolinefifemd.com/2017/06/07/important-message-from-uhms-executive-director-about-prior-authorization-and-hbot/

After the Prior Authorization ended, Targeted Probe and Educate as well as focused pre-payment reviews and post-payment audits started.

https://carolinefifemd.com/2018/03/01/top-ten-reasons-that-the-use-of-hbot-is-down-50-nationally-and-what-you-need-to-do/

The OIG put Hyperbaric Oxygen Therapy Services on their 2017 Work Plan, and in 2018 the OIG came out with two reports:

https://oig.hhs.gov/oas/reports/region1/11500515RIB.pdf
https://oig.hhs.gov/oas/reports/region4/41606196.pdf

Hospitals that submitted claims to WPS and First Coast were found to have error rates of 85% and 92% respectively.

https://carolinefifemd.com/2018/03/28/guest-post-by-dr-helen-gelly-big-bad-news-for-hbot-providers-in-the-wps-j5-jurisdiction/

The number of hyperbaric treatments that have been provided to traditional Medicare beneficiaries has plummeted. We are back to 2009 numbers.

The most recent development is that all the RACs have identified Hyperbaric Oxygen Therapy (HBOT) For Diabetic Wounds as an “approved issue.”

https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Recovery-Audit-Program/Proposed-RAC-Topics-Items/2A094-Hyperbaric-Oxygen-Therapy-HBOT-for-Diabetic-Wounds.html

Since ALL Recovery Audit Contractors have put HBO on their lists, this means that the entire nation will be under audit. They are looking at hospital outpatient departments (G0277) and will be looking back 3 years.

Please make sure that your hospital is aware of this, and that the appropriate departments are put on notice, and that document submission is coordinated with the hyperbaric department, to ensure complete records are sent, with all the supporting documentation.


The Undersea and Hyperbaric Medical Society (UHMS) tries to stay informed about reimbursement challenges. If you are notified of a RAC audit, please alert Dr. Helen Gelly, co-chair of the UHMS QUARC (Quality, Utilization, Authorization, and Regulatory Committee). Do not send patient information. Dr. Gelly can be reached at (770) 422-0517 or HBOwound@aol.com.