AASM advocates for sleep medicine in comments on the 2027 Medicare physician fee schedule and quality payment program proposed rule

The American Academy of Sleep Medicine (AASM) recently submitted comments on the Centers for Medicare & Medicaid Services (CMS) 2027 Medicare Physician Fee Schedule (PFS) proposed rule. The letter outlines the Academy’s recommendations on policies that could significantly affect sleep medicine practices, patient access to care, reimbursement, quality reporting, telehealth, remote monitoring, and emerging technologies.

Key Highlights from the AASM Comment Letter

• Opposed reductions to Medicare physician payment. The AASM expressed significant concern regarding CMS’s proposed 2027 conversion factors and urged CMS to work with Congress on meaningful physician payment reform rather than continuing a pattern of reimbursement instability that threatens physician practices and patient access to care.
• Supported telehealth policy updates. The Academy supported CMS’s proposal to clarify telehealth critical care consultation coding and endorsed policies that continue to modernize telehealth-enabled care delivery.
• Supported greater flexibility in teaching physician policies. The AASM endorsed proposals that would allow telehealth services involving residents and teaching physicians to be furnished under more flexible supervision arrangements while maintaining appropriate oversight.
• Advocated for appropriate valuation of new unattended sleep testing codes. The Academy urged CMS to finalize the AMA RUC-recommended practice expense inputs, equipment time assumptions, and physician work values for the new unattended sleep testing code family to ensure reimbursement accurately reflects the resources required to furnish these services.
• Supported deletion of outdated HCPCS sleep testing G-codes. The AASM recommended retiring legacy sleep testing codes in favor of the new CPT coding framework.
• Opposed proposed reductions to remote monitoring reimbursement. The Academy urged CMS to delay proposed remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) valuation reductions until the agency obtains reliable data regarding the true costs of furnishing clinically integrated remote monitoring services.
• Opposed replacing existing RPM and RTM codes with new bundled Medicare-specific G-codes. The AASM cautioned that the proposal could increase administrative burden, create coding inconsistencies across payers, and reduce transparency regarding the services provided.
• Supported conversion of G2211 into modifier MOD1, provided valuation is maintained. The Academy supported CMS’s effort to simplify reporting but emphasized that the resources associated with longitudinal relationship-based care remain unchanged and should continue to be recognized through equivalent reimbursement.
• Provided detailed recommendations on quality reporting, MIPS Value Pathways, interoperability, electronic prior authorization, FHIR-based digital quality measurement, and future specialty payment models. The AASM emphasized the importance of minimizing burden on practices while ensuring that quality programs remain clinically relevant and operationally feasible.
• Encouraged CMS to consider sleep health as part of Annual Wellness Visit modernization and future AI-enabled preventive care initiatives. The Academy highlighted opportunities to improve identification of undiagnosed sleep disorders through validated sleep-health screening and interoperable digital tools.

Additional Advocacy Through Coalition Efforts

In addition to submitting its own detailed comment letter, the AASM joined two national multi-stakeholder advocacy efforts addressing key provisions in the proposed rule.

• The AASM signed on to an Alliance for Connected Care letter opposing CMS’s proposed remote monitoring policies, including reimbursement reductions and proposed coding changes affecting RPM and RTM services.
• The AASM also signed on to an American Medical Association (AMA)-led coalition letter opposing CMS’s proposal to reduce payment for evaluation and management services billed with modifier 25 when furnished on the same day as a procedure.

The AASM will continue to monitor potential changes to the Physician Fee Schedule and advocate for policies that will improve access to high-quality care for patients with sleep disorders. Members may send questions on the coding and reimbursement sections of the proposed rule to coding@aasm.org and questions on the Quality Payment Program sections to quality@aasm.org.