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<strong>CMS</strong>-1403-FC<br />

Comment: Several commenters state that the best<br />

models utilize high degrees of coordination and<br />

affiliation. The commenters claim that integrated care<br />

models result in higher CPAP compliance and better quality<br />

of care for the patient. The commenters state that the<br />

proposed rule would force integrated sleep management<br />

programs to refer beneficiaries to outside entities for the<br />

CPAP device, thus creating a break in continuity and<br />

accountability. During the public comment period on the<br />

proposed rule, several institutional stakeholders noted<br />

that if finalized unchanged, the regulation would<br />

essentially eliminate integrated sleep management programs<br />

that furnish coordinated management of OSA from testing to<br />

therapy including provision of CPAP. The commenters<br />

claimed that these programs, all facility-based, provide a<br />

level of patient support in ensuring appropriate provision<br />

and titration of CPAP that is not typical with many DME<br />

suppliers. These programs note that under this scenario<br />

they would have reduced ability to monitor the<br />

beneficiary’s compliance with CPAP, including ensuring that<br />

the CPAP device <strong>has</strong> <strong>been</strong> and continues to be optimized for<br />

the individual beneficiary. The commenters believe that<br />

finalization of the proposed rule would remove this option,<br />

734

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