Sleep Study Requirements Apply Despite Removal From DME Policies

In August, the MACs removed sleep testing guidance from the LCDs for PAP, RAD, and Oral Appliances. While no longer included directly in the DME policy, reimbursement still requires a Medicare-covered sleep test with qualifying results. That means suppliers will need to ensure that, before delivering equipment, supporting sleep studies comply with very specific credentialing requirements for sleep labs, interpreting physicians, and technicians outlined in the Part B Polysomnography LCD.

These are not new requirements, but by removing references in the DME policy, suppliers may be more likely to forget these verification requirements and accumulate a significant recoupment liability. Deficiency with a single lab or high-volume physician can affect many patients.

A strong internal practice should periodically:
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1. Review and understand the polysomnography LCD.
2. Verify the applicable credentials for sleep labs, interpreting physicians, and technicians.

Polysomnography LCD

Suppliers can search CMS’s Medicare Coverage Database to find the current Polysomnography LCD. Users can add a state filter on the search results page to minimize duplicated content. For example, choosing “Alabama” from the drop-down state filter, reduces the search results for “polysomnography” from 60 to six:

Suppliers should reconcile the current policy with current practice. If there are any changes, management should make modifications to comply with any new rules. If there are none, the review is a great time to refresh customer service representatives and billing personnel knowledge.

Because LCD changes are relatively infrequent, reviewing the updated policy annually should offer adequate protection. Moreover, sleep labs and doctors that bill for sleep studies and interpretations are subject to the same policy and credentialing requirements, so they must comply with these LCD requirements to ensure their claims are reimbursable.

At present, the LCD imposes three separate credentialing requirements for:

1. Sleep labs.
2. Interpreting physicians.
3. Technicians.

Sleep Labs

Suppliers should only accept test results from labs accredited by one of the following agencies:

• The American Academy of Sleep Medicine (AASM).
• The Accreditation Commission for Health Care (ACHC). 
• The Ambulatory Care Accreditation Program of the Joint Commission.

Furthermore, sleep labs must be affiliated with a hospital or run by a credentialed physician.

Interpreting Physicians

Only physicians certified by one of the following agencies can interpret or approve sleep studies:

• American Board of Sleep Medicine (ABSM).
• American Board of Medical Specialties (ABMS).
• American Osteopathic Association (AOA).

Technicians

Part B policy also contains special credentialing for sleep lab technicians and technologists that attend polysomnography or oversee sleep studies affiliated with home sleep tests. To qualify, these professionals must have one of the following certifications:

• Registered Polysomnography Technologist (RPSGT).
• Registered Electroencephalographic technologist - PSG (R. EEG T).
• Certified Respiratory Therapist - Sleep Disorders Specialist (CRT-SDS).
• Registered Respiratory Therapist Sleep Disorders Specialist (RRT-SDS).
• American Board of Sleep Medicine Registered Sleep Technologist (RST).

Getting Started

Suppliers that have not validated sleep test and professional credentials for a while should:

1. Verify the credentials of all physicians that have ordered PAPs and BiPAPs in the last 12 months.
2. Compile and maintain a list of all referring labs in the supplier’s service area, and verify the laboratory’s credentials.
3. Contact each lab and request a list of technicians employed to facilitate technician verification.

Be sure to print or save all supporting documentation and maintain it in a master file so it is easily producible as evidence in the event of an audit of DME claims. We recommend saving a local copy in case the online database is later changed or becomes unavailable.

SOURCE LINKS
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• https://www.cgsmedicare.com/jc/pubs/news/2021/08/cope22950.html
•  https://www.cms.gov/medicare-coverage-database/search.aspx
• The American Academy of Sleep Medicine (https://sleepeducation.org/sleep-center/)
• The Accreditation Commission for Health Care (https://www.achc.org/find-a-provider/) 
• The Ambulatory Care Accreditation Program of the Joint Commission (http://www.qualitycheck.org/consumer/searchQCR.aspx)
• American Board of Sleep Medicine (http://www.absm.org/listing.aspx)
• American Board of Medical Specialties (https://www.certificationmatters.org/find-my-doctor/)
• American Osteopathic Association (https://findado.osteopathic.org/)
• Registered Polysomnography Technologist (https://brptportal.cobaltsaas.com/Public/Directory.aspx?selmenid=men6)
• Registered Electroencephalographic Technologist (https://abret.org/employers/credential_search/)
• Certified Respiratory Therapist Sleep Disorders Specialist (https://practitionerportal.nbrc.org/directory/all)
• Registered Respiratory Therapist Sleep Disorders Specialist (https://practitionerportal.nbrc.org/directory/all)
• American Board of Sleep Medicine Registered Sleep Technologist (http://www.absm.org/listing.aspx)