Local Coverage Article Response to Comments

Response to Comments: Polysomnography and Other Sleep Studies


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Response to Comments: Polysomnography and Other Sleep Studies
Article Type
Response to Comments
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Article Text
Noridian's Response to Provider Recommendations for Polysomnography and Other Sleep Studies (for comment period ending 12/15/2016)

There were several comments regarding this policy. Many dealt with credentialing of some sort. Similar comments will be grouped.

Response To Comments

1Can you please clarify if the CPSGT is allowed to perform Medicare studies? It is felt by the Contractor that the CPSGT certification is an entry level certification and will not be added to the list of acceptable credentials for this policy. We do not feel these technicians may function independently at this point. See the information below: The CPSGT Certification The Certified Polysomnographic Technician (CPSGT) is an entry-level certification earned by individuals new to the sleep field. It is time-limited; certificate holders must earn the RPSGT credential within three years or lose the CPSGT designation. The Board of Registered Polysomnographic Technologists (BRPT) sets the credentialing standards for the CPSGT certificate and develops, maintains and administers the CPSGT examination for polysomnographic technicians. The CPSGT certificate program reflects a commitment to competency-based testing early in a sleep professional’s career, and requires an early and on-going commitment to continuing education, both cornerstones in enhancing the level of professionalism in the sleep field. To become certified as a CPSGT, a technician must have necessary clinical experience, hold a Basic Life Support (BLS) Certification or its equivalent, adhere to the BRPT Standards of Conduct and pass the CPSGT exam.
2Many were concerned about the credentialing requirements with regard to hospitals. Several comments were received wondering why hospitals must follow the same credentialing options as sleep centers? It was stated that some studies are performed by the hospital staff itself, while other hospitals have contracted out with sleep groups to do the work. It was not felt that these are sleep “centers” and the LCD should not apply to these locations. Further, it was felt the policy language was 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, National Coverage Determinations and the Durable Medical Equipment MAC LCD. Hospitals are not excluded from the requirement to be credentialed for sleep studies that are performed at their sites. All sites and locations must be credentialed. Noridian believes the final draft is clear that any site other than the patient’s home must be credentialed.
3A comment was received requesting a change of language in Section F to “The physician reading/interpreting the sleep study must meet one of the following:…” as opposed to “The physician performing the service must meet one of the following:…” This was felt to distinguish the physician who is reading/interpreting the sleep study from the physician directing the facility in which the study occurs. Because the sleep disorder clinic may not only perform diagnostic testing but also may play a role in treatment, the Contractor believes all components of the work, both technical and professional must be credentialed.
4There were requests for specific language changes to the policy, such as the word “pertinent”, the reference to an EEG in the diagnosis of sleep apnea, alternative descriptions for sleep apnea, “home sleep apnea testing” rather than” home sleep testing” and the number of naps in the narcolepsy section of the policy, to name a few. Italicized writing in the policy signifies the exact language of the IOM. This cannot be changed by the Contractor.
5A list of contraindications was provided for home sleep testing.The Contractor believes that the current policy list captures the most of the contraindications listed.
6A comment was received with a request to clarify that other titration studies, such as Bi-level Positive Airway Pressure (BPAP), Adaptive Servoventilation (ASV) and Average Volume Assured Pressure Support (AVAPS) titration studies be acceptable substitutes for basic CPAP.The policy is written to be in synch with the Durable Medical Equipment Contractors, who have jurisdiction over the coverage of those devices.
7A request was made to add periodic limb movement disorder as an additional covered topic.The Contractor did not feel that the indications could be changed from the italicized statements in the IOM. However, the diagnosis code for periodic limb movement is listed in the ICD-10 code listing on the policy for potential coverage.
8A request was made to have actigraphy considered separately and for separate payment for other sleep disorders excluding sleep apnea and to allow for separate payment when it is used as a pretest for narcolepsy.The majority of such studies are performed during the testing for sleep apnea and would be considered part of that study. The Contractor has no current plans to consider reimbursement of this test separately and will not be adding diagnoses codes for coverage of Actigraphy separately.
9A request was made to add some diagnosis coding for parasomnias. The policy did discuss sleepwalking and night terrors within the verbiage portion but ICD 10 diagnoses codes F51.3 and F 51.4 were added to the Group 2 listing of codes. Confusional Arousals, G47.51 was already present.
10A request was made for the inclusion of ICD-10 code for Hypoxia/hypoxemia R09.02 to be used as medical necessity for a polysomnogram CPT code 95810, 95811.The sleep study is being performed to exclude sleep apnea as a diagnosis or to be sure that treatments for sleep apnea are optimal. The patient may have hypoxia but the purpose of the study is to evaluate suspected sleep apnea or the status of it with treatment. Hypoxia will not be added to the policy.

Associated Documents

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Public Versions
Updated On Effective Dates Status
03/29/2017 06/05/2017 - N/A Currently in Effect You are here


  • •Polysomnography
  • •Other Sleep
  • •Sleep Studies
  • •CPAP
  • •Narcolepsy
  • •Parasomnia
  • •95782
  • •95783
  • •95800
  • •95801
  • •95805
  • •95806
  • •95807
  • •95808
  • •95810
  • •95811
  • •G0398
  • •G0399
  • •G0400