The Centers for Medicare & Medicaid Services is reviewing its national coverage determination (NCD) regarding the diagnosis of patients with OSA requiring CPAP therapy.  Current national coverage policy specifies that only polysomnography done in a facility-based sleep study laboratory can be used to identify patients with OSA requiring CPAP (240.4).

CMS has received a complete formal written Request [PDF, 346KB] from the American Academy of Otolaryngology-Head and Neck Surgery to modify this decision to include the use of portable multi-channel home sleep testing devices as an alternative to facility-based polysomnography in the evaluation of OSA.

In addition, CMS has received an incomplete request from a Medicare beneficiary, numerous informal requests from stakeholders, and interest from Medicare contractors concerning the criteria for determining the Apnea-Hypopnea Index (AHI). The current NCD at section 240.4 states in part “…The AHI is equal to the average number of episodes of apnea and hypopnea per hour and must be based on a minimum of 2 hours of sleep recorded by polysomnography using actual recorded hours of sleep (i.e. the AHI may not be extrapolated or projected).”  It has been suggested by some that this requirement be changed to “the AHI is equal to the average number of episodes of apnea and hypopnea per hour and must be based on a minimum of 2 hours of sleep or less, if the actual number of AHI episodes recorded is 30 or more in less than 2 hours, recorded by polysomnography using actual recorded hours of sleep (i.e., the AHI may not be extrapolated or projected).

We are also aware of recently published research suggesting a benefit for the use of CPAP without prior sleep testing in selected populations (trial of CPAP).

Steve Pearson, MD, MSc, Vice Chair
Steve Phurrough, MD, MPA, Coverage and Analysis Group
Maria Ellis, Executive Secretary

Download meeting minutes [PDF, 2MB].

Download questions [PDF, 40KB] to panel.

Download score sheet [PDF, 23KB].

*5 MINUTES PER SPEAKER*

• Thomas Kehoe, MD, Medical Director, SNAP Laboratories

• Michael Coppola, MD, Associate Clinical Professor of Medicine
  Tufts University School of Medicine

• William C. Dement, MD, PhD, Professor of Psychiatry and Behavioral Sciences at the Stanford University School of Medicine

• Jon Freudman, MD, Freudman Healthcare Consulting, LLC

• Charles Atwood, Jr, MD, American College of Chest Physicians (ACCP)

• David Gourley, RRT, MHA, American Association for Respiratory Care (AARC)

• Lisa M. Getson, Executive Vice President, Clinical Services & Compliance, Apria Healthcare

• Kelly Garber, CRT, Division Clinical Manager, Respiratory Services

• Stephen Burton, PhD, Diplomat, American Board of Sleep Medicine

• Alex Chediak, American Academy of Sleep Medicine (AASM)

• Philip Westbrook, MD, Chief Medical Officer, Advanced Brain Monitoring, Inc.

• Samuel Kuna, MD, Associate Professor, Philadelphia VA Medicare Center, American Thoracic Society (ATS)

• James Parish, MD, The Mayo Clinic

• Mark Goetting, MD, Sleep Health

• David Kuhlmann, MD, ABSM, Medical Director, Sleep Medicine Bothwell Regional Health Center

• Terence M. Davidson M.D., Professor of Surgery, Head and Neck Surgery, Associate Dean for Continuing Medical Education, University of California, San Diego, School of Medicine, Chief Head and Neck Surgery, VA San Diego Health Care System