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July 23, 2026

Proposed Local Coverage Determination (LCD) Released for Comment – Oxygen and Oxygen Equipment

Joint DME MAC Publication

The Centers for Medicare and Medicaid Services (CMS) assigns to the Durable Medical Equipment Medicare Administrative Contractors (DME MACs) the task of developing LCD for Durable Medical Equipment, Prostheses, Orthoses, and Supplies (DMEPOS). The DME MACs are proposing the LCD as described below:

Oxygen and Oxygen Equipment (DL33797): Proposing reasonable and necessary coverage criteria for topical oxygen therapy for Medicare beneficiaries with diabetic foot ulcers that have failed to heal with four consecutive weeks of optimized diabetic foot ulcer care.

Stakeholders may read the details of the proposed LCD posted on the Medicare Coverage Database by referencing the LCD ID number in the search field. The entire proposed LCD should be reviewed prior to the submission of written comments.

We are soliciting comments on the proposed LCD from stakeholders (including, but not limited to, clinicians, manufacturers, suppliers, and other parties who care for Medicare beneficiaries). You should be very specific in your comments and, if possible, offer suggestions that may address your concerns. You should provide an evidence-based rationale for your comments and attach any full-text references from the published clinical literature (for example, peer-reviewed journals, clinical society guidelines, etc.) that were not included in the bibliography of the proposed LCD. We encourage a written response regardless of your agreement or disagreement with the proposed LCD.

In your comments, please be sure to disclose all conflicts of interest you have with any manufacturer(s) or supplier(s) of the DMEPOS items addressed in the proposed LCD.

All comments will be collected at a single point of contact for the proposed LCD. Do not include any protected health information (PHI) or personally identifiable information (PII). Submit your comments electronically to the DME MACs at the applicable email address listed below no later than Saturday, September 5, 2026.

Oxygen and Oxygen Equipment (DL33797): TOTRecon@noridian.com

Response to comments will only be provided in the policy's Response to Comments article if the comments are sent to the proposed policy's designated email address.

If the proposed LCD coverage criteria refer to an LCD-related Policy Article (PA), then a convenience copy of a draft PA document may be attached to the proposed LCD. A draft PA document attached to a proposed LCD is only provided for reference purposes.

Suppliers and clinicians are cautioned not to make any changes based upon information contained in a proposed LCD. The content of a proposed LCD may be revised based upon the written comments received during the comment period. When all written comments have been reviewed, revisions will be considered.

IMPORTANT: The DME MACs will host a virtual open meeting to further solicit input from stakeholders for the proposed LCD. The virtual open meeting will take place on August 26, 2026. For details regarding participation in the virtual open meeting, refer to the open meeting announcement article posted at Open Meeting Announcement – Oxygen and Oxygen Equipment Proposed Local Coverage Determination (LCD).

Refer to each DME MAC website for additional information, including access to the proposed LCD.

Thank you for your participation in our policy development process.

Smitha M. Ballyamanda, MD, CAQSM
Medical Director, DME MAC Jurisdiction A
Noridian Healthcare Solutions, LLC
Robert D. Hoover, Jr., MD, MPH, FACP
Medical Director, DME MAC Jurisdiction C
CGS Administrators, LLC
Sunil V. Lalla, MD, FACS, CPC
Medical Director, DME MAC Jurisdiction B
CGS Administrators, LLC
Angela S. Jenny, DO, DABFM
Medical Director, DME MAC, Jurisdiction D
Noridian Healthcare Solutions, LLC

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