Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
disrupting established integrated sleep management
programs, this final rule with comment period will not
prohibit DME payment to suppliers of CPAP to beneficiaries
who have been diagnosed with OSA using attended
facility-based PSG.
We are unaware of a reliable way to prospectively
distinguish bona fide integrated sleep management programs
from other entities for the purposes of this regulation.
As we note below, there is no currently available
accreditation program under which an entity can, under a
single certificate, be accredited for sleep diagnosis and
the supply of CPAP treatment. Thus we considered how to
balance these concerns and minimize disruptions to
continuity of care while maintaining the necessary
protections for the Medicare program and its beneficiaries.
We believe that creating an exception for
facility-based PSG strikes a reasonable balance of these
concerns. In the context of OSA diagnosis and treatment
for Medicare beneficiaries these integrated sleep
management programs have historically (before the March
2008 NCD) used attended facility-based PSG for OSA
diagnosis, as alternative diagnostic strategies did not
support Medicare coverage of the CPAP device.
736