The AASM recently submitted comments in response to the policy revisions proposed by the Centers for Medicare and Medicaid Services (CMS) in the 2019 Medicare Physician Fee Schedule and Quality Payment Program.

Many of the revisions in the 2019 proposed rule, released by CMS on July 25, were put forth in an effort to prioritize the Patients Over Paperwork initiative, created to reduce burdensome regulations. The AASM performed a thorough review and analysis of the proposed rule and found that several of the proposed revisions may impact sleep medicine coding, documentation and reimbursement, as well as sleep medicine professionals’ participation in the Merit-based Incentive Payment System (MIPS).

Several key highlights from the AASM comments include:

  • Strong opposition by AASM to the lower work relative value units (RVUs) proposed by CMS for the home sleep apnea test CPT codes (95800, 95801, and 95806)
  • AASM’s disagreement with the CMS proposal to collapse payment rates for new and established patients, instead encouraging CMS to support the newly created American Medical Association E/M Workgroup focused on developing an alternative to the current E/M codes and payment rates
  • Support of certain CMS proposals to revise documentation guidelines for Evaluation & Management (E/M) visits
  • Support for the addition of several telehealth codes, including a code for Brief Communication Technology-based Service, e.g., Virtual Check-in and Interprofessional Internet Consultation codes
  • AASM’s strong opposition to the removal of two obstructive sleep apnea measures from two specialty measure sets in 2019 and complete removal of the measures from the MIPS program by 2021:
    • QPP Measure 276 – Sleep Apnea: Assessment of Sleep Symptoms
    • QPP Measure 278 – Sleep Apnea: Positive Airway Pressure Prescribed

All comments received in response to the proposed rule will be reviewed by CMS in advance of publication of the final rule this fall.  The AASM will review the final rule and keep members informed of all final revisions to the Medicare Physician Fee Schedule and Quality Payment Program.

The AASM continues to advocate on behalf of all of our individual and facility members, striving to ensure your ability to continue providing high quality care to the Medicare patient population.

Get more information from the AASM about coding and reimbursement.