Noridian has started sending out letters to notify hospitals of post-payment review of outpatient HBOT charged records from 2018 (G0277).

See below for the pitfalls of writing the usual HBOT note. If you do not order the HBOT for that day, you will likely not get paid. It also requires documentation of daily progress. The problem with “daily progress” is that there is usually no progress to observe daily. It’s possible the “effect” could be that they “tolerated procedure.” The key take home is that for every treatment day that they request, it appears that the whole chart needs to go with the request.

I get scoffed at when I recommend writing daily orders, but there it is in writing.

As usual, Medicare tees it up. CMS put out this article on Documentation Requirements for HBO on Feb 08, 2019: so it has actually been in place for months.



So this is just an extension of what they started earlier in the year. I missed the earlier documentation requirement, but it pretty much follows the TPE and PRIOR AUTH requirements, but is now much more defined.

01-020 Outpatient Hyperbaric Oxygen Therapy (HBO) Notification of Medical Review

Noridian Healthcare Solutions, LLC, as the Supplemental Medical Review Contractor (SMRC) for the CMS, is conducting post-payment review of claims for Medicare Part B of A, Hyperbaric Oxygen (HBO) Therapy billed on dates of service from January 1, 2018, through December 31, 2018. This notification includes the reasons for the review, documentation that will be requested in the Additional Documentation Request (ADR) letter, and resources providers/suppliers may wish to consult when submitting claims.

    1. History and physical, at a minimum should include prior medical and/or surgical interventions and previous HBOtreatments
    2. Physician or Non-Physician Practitioner (NPP) order for date of service
    3. Diagnosis related to the provision of HBOtherapy and all related services to include onset date of diagnosis
    4. Initial evaluation and re-evaluations
    5. Progress/attendance records for each visit billed
      • Description of physical findings
      • Types of treatment(s) provided
      • Number of treatment(s) provided
      • Effect of treatment received
      • Assessment of any progress made
      • Treatment time to support units billed
    6. Documentation of the procedure (logs) including ascent time, descent time and pressurization level. There should be a treatment plan identifying timeline and treatment goals.
      • Valid electronic physician and/or clinician signatures
      • If an electronic health record is used, the Electronic Order Signature Process Form should be submitted to verify provider’s Electronic Ordering System is secure