The AASM has submitted a comment letter in response to the Centers for Medicare & Medicaid Services’ (CMS) calendar year 2027 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule.
The AASM focused on CMS’s proposed payment policies for the new unattended sleep testing Current Procedural Terminology (CPT) code family, which will take effect in 2027. Specifically, the AASM expressed concern about CMS’s proposal to assign moderate-complexity and high-complexity unattended sleep testing services to the same Ambulatory Payment Classification (APC) despite meaningful differences in the technology, resources, and operational costs required to furnish these services. The AASM urged CMS to establish separate APC assignments to better reflect hospital resource utilization, support payment accuracy, and help ensure Medicare beneficiaries maintain access to clinically appropriate diagnostic testing options.
The AASM also highlighted the importance of aligning HOPPS payment policies with the resource distinctions CMS has proposed under the Medicare Physician Fee Schedule. In addition, the AASM emphasized the potential impact on patient access, particularly for Medicare beneficiaries with complex clinical needs and those who rely on local hospital outpatient departments for sleep diagnostic services.
Members are encouraged to submit comments in response to the proposed rule. Comments from clinicians, sleep centers, researchers, and other stakeholders help demonstrate the real-world impact of Medicare payment policies on patient access and sleep care delivery.
Comments must be submitted by Aug. 31, 2026. Members may submit questions about the rule or the AASM response to coding@aasm.org.
