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CMS-1403-FC
thus they believe leading to fragmented care, loss of
accountability and potential harm to patients.
Response: Integrated sleep management programs
furnish comprehensive diagnostic and therapeutic services
with a single coordinated program that commonly includes
ongoing assessment of the patient’s response to therapy and
modifications to therapy as needed.
If finalized as proposed, the regulation would likely
result in these programs referring all beneficiaries to
outside DME suppliers for the CPAP device, thus creating a
break in continuity of care.
This concern, which we recognize with attended
facility-based PSG furnished in integrated sleep management
programs, is not applicable outside of this setting. There
is no substantive claim of continuity of care and
coordinated disease management in other settings where a
sleep test provider may have some other relationship with a
DME supplier.
Our administrative contractors informed us that they
have not historically found these integrated sleep
management programs furnishing attended facility-based PSG
to be a significant vulnerability. We cannot at this time
confidently exclude the possibility that disrupting this
model of care might be harmful to some patients. To avoid
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