Support fair payment of the new unattended sleep testing codes

The American Academy of Sleep Medicine will submit comments in response to the Centers for Medicare & Medicaid Services (CMS) Physician Fee Schedule proposed rule specifically regarding the valuation of the new unattended sleep testing current procedural terminology (CPT) codes (95X18-95X23), which will replace the current codes 95800, 95801, and 95806. The AASM is encouraging sleep physicians, sleep centers, and other stakeholders to submit comments to CMS to support appropriate valuation of these services to help ensure continued patient access to high-quality unattended sleep testing and fair reimbursement for the services provided.

The new unattended sleep testing codes were developed through the American Medical Association (AMA) CPT and Relative Value Scale Update Committee (RUC) processes, in collaboration with the American Academy of Neurology, American College of Chest Physicians, and the American Thoracic Society. The new codes reflect advances in sleep technology, better capture different levels of complexity, and support a broader range of sleep disorders.

Key issues identified by the AASM

1. CMS should not reduce the clinical staff inputs.
The AASM will clarify the clinical staff time and activities associated with unattended sleep testing. These activities include patient education, equipment training, sensor placement instruction, quality assurance review, manual scoring verification, study preparation, and equipment cleaning and repackaging. The AASM will emphasize that these services are essential for obtaining technically adequate studies and reducing the need for repeat testing. The AASM will urge CMS to finalize the RUC-recommended clinical staff times for CA021 and CA042 without reduction.

2. CMS should maintain the proposed 960-minute equipment time.
The AASM will support the RUC recommendation that unattended sleep testing equipment be assigned 960 minutes of equipment time. The AASM will note that the device remains dedicated to a single patient throughout equipment instruction, unattended testing, and the device’s return, making it unavailable to other patients during that period. CMS should retain the proposed equipment time because it accurately reflects typical clinical workflows.

3. CMS should consider additional pricing information before finalizing PE values.
CMS has requested additional invoices and market data to establish pricing for the equipment and supplies associated with the new codes. The AASM will encourage CMS to consider all supplemental invoices submitted by manufacturers, suppliers, sleep centers, and other stakeholders before finalizing direct practice expense pricing. The AASM will express concern that relying on limited pricing data could undervalue the equipment and supplies necessary to provide unattended sleep testing services.

4. CMS should finalize the RUC-recommended work RVU for CPT code 95X23.
Although CMS accepted the RUC-recommended work RVUs for CPT codes 95X21 and 95X22, the agency proposed reducing the work RVU for CPT code 95X23 from 1.60 to 1.42. The AASM will strongly disagree with this reduction because it would undervalue the physician work required to interpret the most complex unattended sleep studies. The AASM will emphasize that these studies require review of multiple physiologic signals, evaluation of data quality and artifacts, identification of respiratory events, and synthesis of findings into a diagnostic report. The AASM will urge CMS to finalize the RUC-recommended work RVU of 1.60.

5. CMS should update the analytic crosswalk.
The AASM will request that CMS update the utilization data analytic crosswalk in the proposed rule to ensure that the code mapping accurately reflects the recommendations developed through the RUC process. As currently proposed, the analytic crosswalk incorrectly assigns a disproportionate share of independent diagnostic testing facility (IDTF) utilization to the moderate-complexity codes rather than the low-complexity codes.

Review the AASM’s comments on the proposed valuation for codes 95X18-95X23 here.
While these comments focus exclusively on the information in the proposed rule related to the new unattended sleep testing codes, the AASM will be submitting additional comments on other sections of the rule that could impact sleep medicine clinicians and practices.

Your comments matter

CMS gives significant weight to comments submitted by physicians and provider organizations. The AASM encourages members and accredited sleep centers to submit comments supporting fair valuation of the new unattended sleep testing codes and emphasizing the importance of preserving patient access to high-quality diagnostic services.

Stakeholder comments that reinforce the AASM’s recommendations can help CMS better understand the clinical work, resources, and operational requirements necessary to provide unattended sleep testing services safely and effectively. Members may download a template letter to assist in preparing a response to CMS regarding the proposed code valuations. We encourage members to personalize these comments by adding details about how these tests are utilized in their own practice or providing invoices for the devices they use.

Refer to this 2027 Physician Fee Schedule Proposed Rule Comment Submission document for instructions on how to submit comments electronically.

What’s next?

Once the public comment period closes, CMS will review all submitted feedback and publish a final rule in late October or early November 2026. All changes, including the replacement of the current unattended sleep testing codes (95800, 95801, 95806) with the new codes (95X18-95X23), will be effective beginning Jan. 1, 2027.

In addition to submitting comments to the proposed rule, the AASM will release a suite of educational resources in the coming months for clinicians, industry, and payers to support the implementation of these codes. Education will include sessions at upcoming courses, new coding FAQs, webinars, a Talking Sleep podcast episode, a quick reference guide for coders, a special updated sleep medicine coding module in Sleep-CODE, and template letters that clinicians can send to payers.

Questions about the AASM comments or the proposed rule comment submission process can be directed to coding@aasm.org.