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CMS-1403-FC
supplier separately. However, we are unaware of any
current model that would encompass both under a single
accreditation certificate. One commenter estimated that it
would take approximately 6 months to develop such an
accreditation framework. We expect that it would take
1 to 2 years to implement and accredit sufficient programs
to make this a viable alternative.
Ideally, we would like to require that all entities
that furnish both sleep testing and CPAP be accredited. We
solicit public input on accreditation models that might
support this option. Once we are made aware of appropriate
accrediting models, we may readdress this issue in future
rulemaking.
Comment: Several commenters expressed concern
regarding the delays from time of OSA diagnosis to time of
CPAP treatment that might arise if the beneficiary is
supplied CPAP from an unaffiliated supplier. The
commenters believe that this will have an adverse impact on
the patient and will affect their follow through related to
the plan of care.
Response: OSA is not an acute condition. We are not
aware of credible evidence of serious harm due to delay of
days or weeks between OSA diagnosis and CPAP treatment.
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