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CMS-1403-FC
for example chronic obstructive pulmonary disease, are
generally diagnosed based on the combined results of
multiple tests such as chest x-rays, arterial blood gas
measurements and pulmonary function tests. Thus it is less
likely that a diagnosis of OSA will be supported by
consistent findings across multiple test platforms. We are
concerned that the provider of a sleep test will have a
bias to interpret an inconclusive sleep test as positive if
that provider has a financial interest in the payment for
the CPAP device that would be used to treat the
beneficiary. We believe that this represents a
vulnerability to the Medicare program.
We believe that we have sufficient reason to believe
that OSA and CPAP are more amenable to fraud and abuse than
some other items and services. We have seen program
vulnerabilities in a similar benefit, specifically oximetry
testing in the home for coverage of the home use of oxygen.
For example, our local contractors informed us that
laboratories and DME suppliers were, without an order from
the treating physician, initiating oximetry testing. As a
result, we acted to prohibit DME suppliers from furnishing
the oximetry testing used in part to establish the
beneficiary’s eligibility for home oxygen coverage.
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