Dear Members,
On Friday the Centers for Medicare & Medicaid Services ( CMS) released Proposed Decision Memo for Continuous Positive Airway Pressure (CPAP) Therapy for Obstructive Sleep Apnea (OSA). The decision is available for download from the CMS Web site at https://www.cms.hhs.gov/mcd/viewdraftdecisionmemo.asp?from2=viewdraftdecisionmemo.asp&id=204&.
I encourage each member to read the memo from CMS as home sleep testing is, without question, the paramount issue in our field currently. This policy will significantly impact how we practice sleep medicine and the landscape of our field. From reading comments posted online in the member's forum I know there is a great deal of concern among our membership. As practicing sleep medicine practitioners, the AASM's leadership and I completely understand your concerns and can relate to them. I am taking this opportunity to touch on the proposed policies within the CMS memo and share the AASM's immediate actions.
As you read the memo, please keep in mind this is a draft of the proposed policy. The final policy from CMS will be published in March 2008. Currently there is a 30-day open period for the public to submit comments to CMS on the draft memo. The AASM leadership is currently crafting a formal, thorough, evidence-based response to the draft memo. This response, which I will outline in this letter, will be communicated to all AASM members once it is completed.
The draft national coverage determination (NCD) from CMS, which is intentionally broad, should not be seen as final. A NCD is a general policy set by Medicare that its Regional Medicare Offices can use as a guide for developing a local coverage determination (LCD). The LCD is the policy that affects your practice. The AASM intends to work with the Regional Medicare Offices to define and shape home sleep testing through LCD policies. It should be noted, however, that some Regional Medicare Offices use the NCD in place of a LCD. More information on Medicare, including the difference between NCD and LCD policies, will be posted on the AASM's Web site in the coming days.
In our response to CMS the AASM will challenge several inconsistencies, inaccuracies, and omissions within the draft memo. In particular, the AASM intends to challenge the inclusion of Type IV portable monitoring devices as acceptable for home sleep testing and the absence of a requirement that home sleep testing be performed under the auspices of an AASM-accredited comprehensive sleep medicine program where a credentialed sleep specialist provides the prerequisite expertise and oversight needed for safe and successful use of home sleep testing. The leadership believes these are among the critical issues that must be raised with CMS before the final memo is published and Regional Medicare Offices begin developing LCDs. Again, the AASM response will be communicated to members, and I encourage you to read upcoming editions of the Weekly Update and Special Updates in order to stay abreast of developments.
As the organization at the forefront of promoting excellence in sleep medicine health care, education and research, the AASM has been the leader for the sleep medicine field on issue of home sleep testing. The evidence-based approach of the AASM has shaped our well-regarded standards, educational programs and standards for accreditation. In response to the CMS NCD on home sleep testing, the AASM is creating new professional resources for members and examining our existing policies and guidelines for possible revision. The Accreditation Committee is meeting this week to examine the Standards for Accreditation in accordance with the Clinical Guidelines for the Use of Unattended Portable Monitors in the Diagnosis of Obstructive Sleep Apnea in Adult Patients published in the December issue of the Journal of Clinical Sleep Medicine. Home sleep testing will be addressed in a special section in the AASM Manual for the Scoring of Sleep and Associated Events : Rules, Terminology and Technical Specifications. New educational content and brochures on home sleep testing will developed for your patients and available on the AASM public education Web site www.sleepeducation.com. Lastly, the AASM is developing a series of interactive webinars on home sleep testing for each region of the country. Look for more information on these initiatives in the coming weeks.
I encourage you to visit
www.aasmnet.org/PortableMonitoring.aspx, a section of the AASM Web site devoted to home testing that includes links to all relevant CMS decisions and policies as well as AASM testimony to the MedCAC and the newly published Clinical Guidelines for the Use of Unattended Portable Monitors in the Diagnosis of Obstructive Sleep Apnea in Adult Patients. I encourage you to carefully read the new AASM guidelines and be aware of the AASM's position on home sleep testing. The CD-ROM edition of
Portable Monitoring Discussion Forum, a webinar held on Tuesday, is available for purchase by visiting
www.aasmnet.org/store/products.aspx.
Lastly, I welcome your comments on home sleep testing and encourage an open dialogue among the membership. Log on to www.aasmnet.org/Members/forums/ and post your comments in the member's forum. I will be posting comments in the forum periodically in response to your questions and concerns.
The leadership and staff are closely monitoring the issues related to home sleep testing and I will be writing to you in the coming months on the actions of CMS and the ongoing AASM initiatives. In the meantime, I encourage you to visit the AASM Web site often for news on our initiatives and resources.
Alejandro D. Chediak, MD
President