Notice: This CMS-approved document has been submitted - Philips ...
Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...
CMS-1403-FC Comment: One commenter stated concerns that the rule will limit appropriately trained and qualified DMEPOS suppliers’ ability to furnish home sleep tests. The association claims that the rule creates unnecessary and artificially high barriers to DMEPOS suppliers’ ability to furnish services that are uniquely within their area of expertise. The commenter stated that the DME business model is premised on the ability to furnish medical equipment to patients in their homes and DMEPOS suppliers may be the only providers with the immediate capacity to furnish HST to Medicare beneficiaries. Response: Only the physician treating the beneficiary can order a HST and prescribe CPAP therapy. We expect that the sleep test would be interpreted by a physician, and we do not believe CPAP suppliers should be paid for supplying CPAP equipment when an affiliated physician has interpreted the HST or ordered the equipment. We are not persuaded that DME suppliers have any uniquely valuable expertise in the provision of diagnostic testing. Comment: Many commenters claimed the regulation will result in an under availability of CPAP equipment and services in many communities. One commenter explained that IDTFs are now permitted to utilize HST to diagnose OSA, but point out that the vast majority of IDTFs do not have the 746
CMS-1403-FC resources and infrastructure needed to deliver or pick-up HST equipment to and/or from the beneficiary’s home. The commenter requested that CMS furnish a detailed analysis on beneficiary access to CPAP supplies and services locally before implementing such a provision. Response: This rule does not prohibit IDTFs from establishing and maintaining sufficient resources and infrastructure to deliver or pick up HSTs, so long as the DME supplier who will be furnishing the CPAP to the beneficiary as a result of the HST is not the same DME supplier that the IDTF has affiliated with for purposes of delivering or picking up the HSTs or performing other functions related to providing the HST. In addition, the exception we are providing for attended facility-based PSG is sufficient to maintain beneficiary access at historical levels before the 2008 NCD. Comment: One commenter stated that the mission of all nonprofit healthcare systems includes furnishing care for the under and un-insured populations. The commenter stated that healthcare systems would no longer furnish sleep tests to the under and uninsured if the healthcare system is prohibited from furnishing CPAP devices to Medicare beneficiaries. 747
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<strong>CMS</strong>-1403-FC<br />
resources and infrastructure needed to deliver or pick-up<br />
HST equipment to and/or from the beneficiary’s home. The<br />
commenter requested that <strong>CMS</strong> furnish a detailed analysis on<br />
beneficiary access to CPAP supplies and services locally<br />
before implementing such a provision.<br />
Response: <strong>This</strong> rule does not prohibit IDTFs from<br />
establishing and maintaining sufficient resources and<br />
infrastructure to deliver or pick up HSTs, so long as the<br />
DME supplier who will be furnishing the CPAP to the<br />
beneficiary as a result of the HST is not the same DME<br />
supplier that the IDTF <strong>has</strong> affiliated with for purposes of<br />
delivering or picking up the HSTs or performing other<br />
functions related to providing the HST. In addition, the<br />
exception we are providing for attended facility-based PSG<br />
is sufficient to maintain beneficiary access at historical<br />
levels before the 2008 NCD.<br />
Comment: One commenter stated that the mission of all<br />
nonprofit healthcare systems includes furnishing care for<br />
the under and un-insured populations. The commenter stated<br />
that healthcare systems would no longer furnish sleep tests<br />
to the under and uninsured if the healthcare system is<br />
prohibited from furnishing CPAP devices to Medicare<br />
beneficiaries.<br />
747