The American Academy of Sleep Medicine has submitted comments to CMS, offering feedback on CMS-1403-P, a proposal that would change Medicare Part B payment policy. The AASM applauded CMS’ attempts to prevent fraud but called the policy "unnecessarily prohibitive and one that ultimately compromises patient care."
Among the provisions, CMS-1403 proposes “to add new definitions to paragraph (a) to define ‘sleep test’ and ‘CPAP device’ and to add a new paragraph (f), which would establish a specific payment prohibition that would not allow the supplier to receive Medicare payment for a CPAP device if that supplier, or its affiliate, is directly or indirectly the provider of the sleep test used to diagnose a beneficiary with OSA.”
In a letter to Steve Phurrough, MD, MPA, director of coverage and analysis group for CMS, the AASM suggests that a rural provider exemption should be included in 1403-P with the following criteria: “The provider is located in an area designated by CMS as rural; and substantially all of the services provided at the site are conducted on individuals residing in a CMS-designated rural area.”
Based on the premise that the AASM is “unaware of fraud or abuse issues related [to] the distribution of CPAP as a durable medical equipment (DME) at facilities accredited by the AASM,” the academy also contends that “AASM-accredited facilities should be exempt from the policy to ensure continuity in care for sleep disorders patients.”
