The AASM is keenly aware of issues that members have been having with coverage of diagnostic tests and treatment during audits due to inconsistencies between AASM clinical practice guidelines and Centers for Medicare & Medicaid Services (CMS) coverage policies, as well as between CMS national and local coverage determination (LCD) policies. The AASM continues to advocate for changes to CMS policies, to encourage CMS to align reimbursement requirements with AASM clinical practice guidelines, and to ensure appropriate reimbursement for sleep services so that patients receive timely and effective evidence-based care. The AASM has been communicating with CMS regarding problematic requirements within coverage determinations and articles, including:
- Incorrect coding and place of service requirements
- Inconsistency between audit criteria and policies included in coverage determinations
- Appropriate billing for split or shared visits
Noninvasive ventilation and Medicare
The AASM also recently participated in a multi-specialty effort to submit a request for reconsideration for the noninvasive ventilation national coverage determination (NCD). A technical expert panel was convened by the American College of Chest Physicians (CHEST), which also included the AASM, American Thoracic Society (ATS), and the American Association for Respiratory Care (AARC). This group ultimately submitted a revised NCD to CMS for consideration and published five papers in the CHEST journal with recommendations and rationale for the requested changes to the policy in the areas of obstructive sleep apnea, central sleep apnea, hypoventilation syndromes, COPD, and thoracic restrictive disorders. The societies are now working to open a dialogue with CMS to understand the timeline for when these changes may be considered and how to best advocate for changes in the areas that may not be prioritized by CMS.
Advocacy strategy and resources
The AASM is working closely with its lobbying firm, McDermott Will & Emery, to devise a strategy to further impress upon CMS that these coverage issues are significantly impacting our members and require immediate attention. The AASM Coding & Compliance Committee is also developing a Medicare Audit Toolkit to assist members in preparing for and navigating future audits. The toolkit will include an audit preparation checklist, responses to frequently asked questions, a sleep center audit resources document, and more.