For Congress, the FDA & Medicare

·           Return Liquid Oxygen to Fee Schedule Payment

ATS 01 (ama-assn.org)  -  https://www.ama-assn.org/system/files/2019-05/a19-119.pdf

·           The FDA Needs to Regulate Portable Oxygen Concentrator Settings so They Are Equivalent to LPM

POC’s oxygen pulse-dose settings do not correspond to continuous ‘liters/minute’ flow rates prescribed by most providers.  https://www.thoracic.org/patients/patient-resources/resources/portable-concentrators-garvey.pdf

You need to be tested on your selected portable oxygen concentrator to confirm it is meeting your oxygen needs.  https://www.nationaljewish.org/education/patient-education/print-multimedia/materials-printer?nodeId=c0a1fa54-bf43-4748-814f-f81e6fe4865d&partnerId=MS

·           Liquid Oxygen Needs to be Widely Available for Those Who Require 3 LPM of Ambulatory Oxygen

In patients with chronic lung disease who are mobile outside of the home and require continuous oxygen flow rates of >3 L/min during exertion, we suggest prescribing portable liquid oxygen.  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7667898/pdf/rccm.202009-3608ST.pdf

·           For Individuals With COPD But No History of Type 2 Respiratory Failure A Target Sp02 of 88% to 92% Is Not Necessary for All and I Believe Has Negative Health Consequences.  Oxygen therapy and inpatient mortality in COPD exacerbation

One-year mortality

Mortality at 1-year post discharge in those treated with supplemental oxygen

In patients who received supplemental oxygen on admission and survived to discharge, the risk of death at 1year was 28%. The 12-month mortality rates, excluding inpatient deaths, were: 87% or less=32%, 88%–92%=31%, 93%–96%=23%and 97%–100%=28% (including inpatient deaths these figures were 43%, 37%, 32% and 40%) (figure 3). The 93%–96%group had a significantly lower risk of death than the 88%–92%group, and overall (online supplemental table 5 includes further information relating to 1-year mortality).

·        Using Horse Sense, More Research and Better Education On Blood Oxygen Levels Is Needed for All Who Respiratory Diseases Touch.  Congress, Medicare, the FDA, Pulmonologists, Doctors and Respiratory Therapists Should Pay Attention to the Horse Sense Part. 

I have a better understanding of what I am discussing if horse sense is used.  Using Medical terms often leaves me wondering what was said or meant.  It could also be regurgation of rote learning  which I am sure, “all with COPD should keep their Sp02 between 88% and 92%” is.


Medicare needs to:

·         Regulate POC and conserving devices settings so they are equivalent to LPM.

·         Require a high and low LPM on prescriptions.

POC manufacturers and salespeople encourage people to believe that POC setting are equivalent to LPM without actually saying it or hiding it deep in the manual or instructions that come with the POC.

Misleading statements from POC manufacturers and sales organizations



Arnold et al. BMC Pulmonary Medicine 2011, 11:9 http://www.biomedcentral.com/1471-2466/11/9

Ambulatory oxygen: why do COPD patients not use their portable systems as prescribed? A qualitative study






These are my thoughts and experiences, not medical advice.

Gerald(Skip) Miller

Contact   hors.sens1@gmail.com
Copyright © 2022 Gerald Miller. All Rights Reserved.