Local Coverage Article Response to Comments

Response to Comments: Polysomnography and Other Sleep Studies (L36839)


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Article Title
Response to Comments: Polysomnography and Other Sleep Studies (L36839)
Article Type
Response to Comments
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This article summarizes the comments WPS received for Draft Local Coverage Determinations (LCD) Polysomnography and Other Sleep Studies, DL36839. Thank you for the comments.

Response To Comments

1The American Academy of Sleep Medicine (AASM) scoring criteria for hypopnea is 3% and “CMS" has 4% proposed. It would be beneficial to all if the same definition or scoring criteria was used by all insurances. Also A/B and DME contractors should be consistent in wording and add history of A-fib, supraventricular tachycardia. Adherence criteria and requalifying for DME is inconsistent and costly.The policy is written to be consistent with the Durable Medical Equipment (DME) and National Coverage Determination (NCDs) policies. And A/B MAC does not set DME rules or policies.
2Inquiry as to why new policy was written with current sleep policy. Changes have been made to match the national Durable Medical Equipment (DME) policy. Often, non-accredited people are billing the federal government for services, and sleep studies are a major issue reported by OIG and law enforcement. The policy seeks to clarify which services qualify as sleep studies, what providers can order and perform them, and seeks to more clearly define home sleep testing.
3Why requirement if patient doesn’t proceed with treatment within 90 days of study must have a face to face with PCP to order another diagnostic sleep study before treatment can be again initiated, or patient discontinued sleep apnea treatment, more than 60 days, required to do new face to face visit with PCP to order new diagnostic sleep study before treatment can proceed.This question submitted is in reference to the requirements of the DME L33718 Positive Airway Pressure (PAP) Devices for the Treatment of Obstructive Sleep Apnea and this is addressed by DME and not by our MAC LCD.
4Many hospitals are choosing to be accredited by DNV-GL Healthcare division. WPS has specifically included DNV-GL on other LCDs, such as: L35755, L35751 L35761. Would you please include DNV-GL as an approved accrediting body for DL 36839?DNV GL - Healthcare has formed an alliance with the Accreditation Commission for Health Care (ACHC). WPS does have ACHC as a credentialing option. WPS does not have plans to add DNV-GL.
5Several templated emails were received wondering why hospitals have to follow the same credentialing options as sleep centers. Some studies are performed by the hospital staff themselves and other hospitals have contracted out with sleep groups to do the work. We do not feel that these are sleep “centers” and this LCD should not apply to these locations. We feel the policy language is unclear and confusing to hospitals who have contracted with accredited Sleep Disorder Clinics to perform sleep studies at a hospital. Hospitals are not Sleep Disorder Clinics and are not defined as such under this policy. Medicare has a defined benefit for Polysomnography and other sleep studies. Every attempt was made to write the LCD according to the benefits as described in the Medicare Manual, the National Coverage Determinations and the Durable Medical Equipment MAC LCD. Hospitals are not excluded from the requirement to be credentialed for sleep studies to be performed at their site. All sites and locations must be credentialed. WPS believes the final draft is clear that any site other than the patient’s home must be credentialed.

Associated Documents

Related Local Coverage Documents
L36839 - Polysomnography and Other Sleep Studies
Related National Coverage Documents
Public Versions
Updated On Effective Dates Status
12/19/2016 02/16/2017 - N/A Currently in Effect You are here