Now more than ever, sleep medicine is on the radar of the Centers for Medicare & Medicaid Services (CMS) and the Office of the Inspector General (OIG). The AASM strongly recommends that all sleep facilities develop a compliance program, including regular file audits, to help ensure appropriate documentation and billing. AASM members and their coding and billing staff are encouraged to attend the upcoming Compliance Program Development Workshop on Friday, Sept. 16 at the AASM national office in Darien, IL.

On Tuesday, Aug. 9, the AASM sent a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining concerns regarding the 2012 Physician Fee Schedule Proposed Rule. The AASM comment letter focuses on the four issues included in the full article. Comments to CMS are due by Aug. 30 using the contact information found on the first page of the Proposed Rule.

By Sunday, Jan. 1, 2012, all HIPAA-covered entities are required to be compliant with Version 5010, the new version of the X12 standards for Health Insurance Portability and Accountability Act (HIPAA) transactions. CMS has designated the week of Aug. 22-26, 2011, as National Version 5010 Testing Week to assist in the transition and to encourage providers to perform external testing (Level II) with their Medicare Administrative Contractors (MACs).

Is your office preparing for a smooth transition to ICD-10 on Oct. 1, 2013? To assist you in your preparation, the Centers for Medicare & Medicaid Services (CMS) is going to host a national provider call on "ICD-10 Implementation Strategies for Physicians" on Wednesday, Aug. 3, 2011, from 1 p.m. to 3 p.m. EDT. CMS subject matter experts will discuss ways that physician offices can prepare for the change to ICD-10 for medical diagnosis and inpatient procedure coding. A question and answer session will follow the presentations.

On July 8, the AASM announced that the Centers for Medicare & Medicaid Services (CMS) had released the display copy of the 2012 Physician Fee Schedule Proposed Rule, which is being reviewed and analyzed by AASM staff. This week the Proposed Rule was published online in the Federal Register. The final decisions on the proposed policy and payment changes are scheduled to be published in November 2011 in the final rule.

As an additional resource, the AASM has developed a template letter to assist members in drafting a response to the CBR Producer. This two-page form letter can be used in whole or in part, and it should be modified to reflect the specifics of each member’s practice. Members interested in responding to the CBR are encouraged to send a personally modified version of the form letter or their own individually crafted letter to the CBR Producer.

The AASM’s letter outlines the potential difficulties that sleep specialists will run into when prescribing hypnotics and stimulants in states that do not allow these medications to be prescribed electronically.

The AASM has received feedback from a number of members regarding the recent memo from Dr. Strollo about the Comparative Billing Reports (CBRs) that have been issued on behalf of the Centers for Medicare & Medicaid Services (CMS).  A number of members’ questions relate to how one can contact Medicare regarding the CBR content.