Federal Communications

Review letters that have been sent to the Centers for Medicare & Medicaid Services (CMS), public payers, and other federal agencies to advocate for issues important to sleep medicine.

• CMS response re: End of PHE (5/18/23)
• DHHS and CMS – End of Public Health Emergency (4/4/2023)
• DEA – Telemedicine prescribing of controlled substances (3/31/2023)
• Noridian, LLC – Audit Retesting Medical Necessity (5/4/2022)
• Billing for Split or Shared Visits (3/29/22)
• Missouri Medicaid Telehealth Changes (2/14/22)
• Treatment Emergent CSA Coding (1/13/22)
• Hypoglossal Nerve Stimulation LCD (Palmetto GBA) (1/3/22)
• DME MACs – Philips PAP Recall (6/22/2021)
• CMS – Prior Authorization Proposed Rule Comments (1/4/2021)
• CGS Administrators, LLC – Inclusion of Snoring Diagnosis Code (5/12/2020)
• CMS – Coverage Criteria for Positional OSA Treatment (6/5/2020)
• US Department of Health and Human Services – Office Visit Payment Policy and Budget Neutrality (7/1/2020)
• DME MACs – Standard Written Orders (9/3/2020)
  • Response letter from DME MACs (9/9/2020)
• CMS – 2021 Physician Fee Schedule and Quality Payment Program Proposed Rule Comments
  (10/5/2020)

AASM Collaborates to Advocate for Changes to CMS Coverage Determination

The American Academy of Sleep Medicine is participating in a multi-society advocacy effort, the Optimal NIV Medicare Access Promotion Technical Expert Panel (ONMAP TEP), which was convened to outline and promote new criteria that would eliminate current regulatory barriers for optimal care delivery for patients with chronic respiratory failure requiring nocturnal NIV. This multi-society effort, convened by the American College of Chest Physicians (CHEST), includes AASM, the American Thoracic Society (ATS) and the American Association of Respiratory Care (AARC). The participants convened virtually for a two-day conference, presenting concerns with the current National Coverage Determination (NCD) to the Centers for Medicare & Medicaid Services (CMS) on day one. On the second day of the conference, each subgroup highlighted changes that should be made in the NCD. Each subgroup drafted a report of their findings and recommendations, accompanied by an executive summary of all recommendations. The below reports were all published in the CHEST journal and the recommendations were submitted to CMS.

• Executive Summary
• Patients with Hypoventilation Syndrome
• Patients with COPD
• Patients with Thoracic Restrictive Disorders
• Patients with OSA
• Patients with Central Sleep Apnea

The ONMAP TEP submitted an NCD Reconsideration Request to CMS, along with draft language for a revised NCD.

• Society joint response to CMS (4/26/22)
• CMS NCD Reconsideration response (2/16/22)
• CMS NCD Reconsideration Request (9/9/21)