O2 Cylinder on a Wheelchair

Q: In a recent posting on oxygen tanks, I didn't see you address labeling. We got written during a recent survey for having a wheelchair in an equipment storage room that had a cylinder attached to it that was neither labeled "FULL" nor "EMPTY". Because it wasn't in the corridor or patient room, it was considered in storage (a nurse was trying to clear the hallway for the survey). Would you speak to this? Thanks!

A: That is a cheesy finding by the surveyor. CMS issued an S&C memo 07-10 dated January 12, 2007, that explains the O2 cylinders attached to wheelchairs are considered “in use” and not “in storage.” The memo does not limit the O2 cylinders attached to a wheelchair to be located in a corridor and there is no basis for a finding that an O2 cylinder attached to a wheelchair in a storage room is considered “in storage.

Since you are not able to clarify findings away any longer, just comply with the finding in the report. However, now that you have knowledge of the CMS memo that permits O2 cylinders on wheelchairs to be considered “in use” regardless where the wheelchair is, you can challenge this finding in the future before it is written into the report.

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