AASM Weighs in on Proposed CPAP NCD

Current policy requires a sleep test, or polysomnography, to be
performed in a facility-based sleep lab, but the agency has
recommended changes, which, among others, would allow the use of
home sleep testing.

Among those to weigh in was the American Academy of Sleep
Medicine (AASM), which sent a four-page response to the proposed
decision memorandum, issued Dec. 14. (See
HomeCare Monday, Dec. 17, 2007.)

AASM challenged what it calls “inconsistencies and omissions”
within the draft memo. In particular, the Academy said it is
contesting “CMS’ inclusion of Type IV portable monitoring devices
as acceptable for home sleep testing, and raising concern over the
vagaries regarding an acceptable CPAP trial, requirements for
clinical evaluation and a paradigm for follow-up and long-term
management.”

In addition, the AASM pointed to concerns regarding the evidence
CMS used as the base for its proposed decision, noting that “the
studies cited in the proposed draft did not include the patient
population covered by Medicare.” AASM also said other important
topics are not addressed in the proposed decision, including
documentation of OSA and determination of severity, which, the
Academy contends, is best measured through in-lab
polysomnography.

Among issues the Academy addressed:

–“The proposal fails to define the measures by which any
physician, especially those inexperienced and untrained in sleep
medicine, would assess the benefit of therapy and also does not
call for long-term management through programs that emphasize
education and follow-up care.”

–“While the AASM supports the use of Type II and III [home
sleep testing] devices by board certified sleep specialists in
patients with a high pre-test probability of moderate to severe
[OSA], it does not support the indiscriminate use of HST by
physicians untrained in sleep medicine.”

–“Consistent with its clinical guidelines, the AASM supports
Type II and III HST devices. However, the AASM does not support the
inclusion of Type IV HST devices.” Such devices have only one or
two monitoring channels, the Academy said, the use of which “makes
ripe the potential for substandard patient care and a substantial
increase in unnecessary tests.”

While AASM supports some of the recommendations in the CMS
draft, the organization said CMS needs to clarify who exactly is
covered by the NCD and answer additional questions before rendering
its final coverage determination.

View CMS’ proposed
decision memo.