While applauding CMS’ attempts to prevent fraud, the American Academy of Sleep Medicine (AASM) called CMS’ 1403-P proposal “unnecessarily prohibitive, and one that ultimately compromises patient care.” The statement came in the form of recently submitted comments from AASM, which also offered additional  feedback on the proposal that would change Medicare Part B payment policy.
 
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.”