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

CMS-1403-FC
services that are properly within the scope of practice of
the beneficiary’s physician, and we would not expect to
receive claims for Medicare payment for such services.
Comment: Several commenters suggested that accredited
entities should be exempt from the prohibition. Some
commenters have proposed that facilities that have been
accredited by a recognized accrediting body to provide full
diagnostic, therapeutic, and DME services should have an
exception from the prohibition required as stated in the
proposed rule.
Response: We agree that an entity that has been
accredited by a recognized sleep therapy accrediting body
would likely have protections in place that would minimize
the potential fraud and abuse concerns we addressed above.
We believe that the scope of such accreditation programs
should be broad enough to include OSA diagnosis and the
supply of CPAP treatment under a unified certificate.
We have contacted JCAHO and AASM (American Academy of
Sleep Medicine) to determine whether either has an
accreditation program that could be applied to an
integrated sleep management program that includes complete
patient management to include managing the DME. AASM
accredits sleep testing but not DME; JCAHO has nonspecific
criteria that might be applied to the testing and DME
738