In response to a Centers for Medicare and Medicaid Services (CMS) request for input on how to address any undue burden of the Stark Law, the AASM submitted comments recommending exceptions for the provision of  positive airway pressure (PAP) therapy for obstructive sleep apnea (OSA) and for alternative payment model (APM) participants.

The AASM comment letter asserts that the Stark Law has created a barrier to quality care for Medicare patients with OSA and is incompatible with today’s goal of providing value-based health care.