Comment on CMS National Coverage Determination
on CPAP


As an experienced medical professional in the
field of heart failure patient management, I am
pleased to submit these comments to the CMS in
response to the open Nat   More...

I wholeheartedly support the use of ambulatory
home monitoring for obstructive sleep apnea.

Patients clearly report disturbances in going to
the hospital, being strapped up and being told to
sleep normally through the night.
   More...

The position statement from the Academy of
Otolaryngology is worrisome. It is a painful
demonstration of a limited knowledge base in both
sleep medicine as a field and in the fundamental
capacity to diagnose and treat the obstruct   More...

Dear Dr. Rollins,
I am writing this letter to you in support of
portable monitoring and diagnosis of sleep
disordered breathing. As a practicing sleep
specialist, I and my colleagues struggle every
day with some patients who re   More...

sleep medicine is under an exponential influx of
new information associating sleep disorders with
a growing number of serious illnesses; its seems
inappropriate at this stage to take short cuts on
the gahtering of data as we obtain   More...

I recommend extreme caution when considering the
role of home testing in sleep testing. I do
think there is a limited role in sleep testing,
such as in the case of an elderly or ill patient
unable to transport to a sleep center. I   More...

Thank you for your interest in comments
regarding an additional forum for providing
sleep diagnostics. As a Respiratory Practioner
of the past 20 years and involved in sleep
medicine for close to 26 years, I have seen the
curr   More...

Patients with dangerous sleep disorders would
have better access to treatment, insurers could
save millions, and the home medical equipment
industry would benefit from an expanded line of
business if new technology in obstructive s   More...

Staff attended sleep studies will assure patient of the best diagnostic and treatment outcome.Without staff present changes occurr that are not able to be correlated to patient position, electrode malfunction and also patient   More...

Steve Phurrough, MD
Director of Coverage & Analysis Group
Center for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Re: Coverage of Home Sleep Testing

Dear    More...

By oferring patients the opportunity to have a
sleep study in the comfort of their own
environment, we can offset the amount of people
who are currently unwilling, or physically unable
to get to a lab. I still beleive the lab base   More...

I am writing to discourage the coverage of
unattended PSG's.

First, the contention that there is currently
limited access to or availability of sleep
studies is not the case in our area. Two sleep
laboratories have clo   More...

Amercian College of Chest Physicians (ACCP)


April 12, 2007

James Rollins, MD, MHSA, Ph.D.
Centers for Medicare and Medicaid Services
Office of Clinical Standards and Quality
Coverage and Analysis Group
Attn   More...

04-10-07


Re: Home Sleep Studies

As RPSGT’s, we are vehemently opposed to the
proposition of allowing home sleep studies to be
performed and covered by Medicare. In our
hospital based sleep lab, we believe in and
s   More...

I believe that in home testing would benefit a
large number of individuals that need testing
for OSA that are unable to utilize traditional
sleep labs.Insurance polocies should cover these
tests.

Date: 4/12/2007

TO: Centers for Medicare & Medicaid Services

FROM: Jeremy Canary A.S., RRT

RE: Public Comment re: Obstructive Sleep Apnea home testing (Ref: CAG-00093R2)

I am writing    More...

The massive backlog of patients at risk for
obstructive sleep apnea needs to be addressed by
allowing home testing with ambulatory devices. It
is well documented in the medical literature that
OSA risks and exacerbates HTN, DM, CAD   More...

As a physician and sleep specialist I stongly
oppose any changes in CMS regulations regarding
home testing for sleep apnea. To my knowledge
there has been no good clinical evidence that
home testing improves medical care, patient <   More...

I do NOT feel it is in the patient's best
interest to allow home testing. Quality of
monitoring/testing would diminish. There are too
many factors that require attention by an
attended sleep technologist during the study
perio   More...

TO: SSI/CMS Clinical Review
RE: OSA Information

I am very pleased that ambulatory sleep testing
is becoming more accessible for my patients. It
is also easier to refer patients for this
necessary evaluation and receive the a   More...

I have been a sleep medicine technologist for over 20 years. I have witnessed many changes within the field. Alot of good, some aweful. Allowing at home monitoring was tried a few years ago with poor success. Our sleep center performed    More...

I support the coverage of ambulatory sleep studies at home such as the test available with the Itamar Watch PAT. It is less costly and more effective than regular sleep lab alternatives. Accessibilty to this technology would save insure   More...

As a head and neck surgeon, I have diagnosed and
treated over 2000 patients with sleep disordered
breathing. The majority of insurance companies
in San Diego reimburse for home sleep tests, and
I have used these tests in all patie   More...

Limited home testing for compliance reasons,
slight PAP changes for comfort are wonderful
options for home CPAP testing and are certainly
not a replacement of diagnostic exam results for
standard clincal tests.

The client st   More...

There have been a couple extensive reviews of the
literature by the leading societies of sleep
medicine physicians and associations: American
College of Chest Physicians (ACCP), American
Thoracic Society (ATS) and American Academy    More...

The National Sleep Foundation (NSF) is an
independent, non-profit organization that is
dedicated to improving public health and safety
by achieving understanding of sleep and sleep
disorders, and by supporting sleep-related
edu   More...

I believe that the ability to have a sleep study
performed in home would be an amazing benefit for
beneficiaries. A great percentage of the patients
that require a CPAP are morbidly obese and
homebound. Therefore a great number of    More...

I am very much for in the home testing for Sleep
Apnea but would like to see it rolled out with
restrictions. I have seen many patients that are
unable to leave the home sadly often due to
Obesity or other medical conditions. The <   More...

I do not think that unattended home testing is a
good idea, as a matter of fact, it can be
dangerous. There are so many variables, so many
things to consider when titrating CPAP on
patients. These people need to be monitored as <   More...

subject: CAG-00093R2

I am a physician with sleep board certification.
I believe that unattended home sleep studies (
such as the "watchpat" system) provide vastly
inferior data compared with attended overnight
polysomnogra   More...

This is a comment re: home testing of OSA and
possible insurance coverage thereof. I am writing
as I have personal experience in home sleep apnea
testing with and without CPAP and I have reviewed
the Watch-PAT (WP) literature.
<   More...

April 11, 2007

RE: Comment Period National Coverag   More...

I am writing to oppose the approval of unattended
sleep studies. Attended sleep studies are not
only the gold standard for treatment of OSA, but
reflect a commitment to accurate and complete
diagnoses. Approving unattended sleep    More...

I am confused. I thought this was for OSA Home
Testing. My comment for OSA Home Testing with
the Watch-PAT 100 is that there is too much room
for error using this device. You don't have the
registered technologist input or the vi   More...

I am M. Boyd Gillespie, MD, Associate Professor of Otolaryngology- Head and Neck Surgery at the Medical University of South Carolina in Charleston.

In response to your query:

(1) I propose no change be made at this time in the    More...

I disagree with this request. I have been doing
sleep studies for 6 years and this is a bad
idea. Sleep stages should be scored and what
about leg kicks. I haven't read an article about
ruling out if a patient has restless legs    More...

In no way, shape or form is an unattended sleep
study to diagnose Obstructive Sleep Apnea
appropriate.

Obstructive Sleep Apnea is a multi-factorial
disease state who's symtoms can are similar to
other sleep disorders. Also,    More...

As a practising respiratory therapist with over
28 years in home care, I agree that there is a
definite role for home testing for treatment of
OSA. I would specifically suggest that Medicare
consider reimbursement for titration of    More...

The American Sleep Apnea Association (ASAA) is the
only national non-profit patient interest
organization dedicated to education, support and
advocacy on the issue of sleep apnea. The
association expressed its concerns on the issue of<   More...

As the coordinator of sleep disorders center
accreditied by the American Association for Sleep
Medicine, I see the importance of CPAP use in
patients with OSA on a daily basis. The key to
compliance for these folks is that the cor   More...

The American Academy of Sleep Medicine (AASM) has
recently issued an RFI and has or is about to
award a grant for a definitive multi-center study
of portable home sleep testing compared with
facility based testing.

It is pr   More...

Insurance providers, including the government,
should be leery of paying for nocturnal home
"sleep studies" because:
1)They do not meet the standards of care set by
the authoritative body in sleep medicine, The
American Academy of S   More...

I've been setting up CPAP's for nearly 10 years
and I have always felt that 'the majority' of my
patients could have been studied in their own
bedrooms. However, there are some folks that would
need proper supervision, i.e. a formal sl   More...

With the advancement of technology and the
perfecting of firmware in auto-titrating CPAP
equipment manufactured today, in-home sleep test
are more reliable than a one-night split study in
a sleep lab. The in-home study can be run    More...

Most of the inhome testing devices don't have the
capability of determining sleep. How would you
know if the pt was asleep or awake? Please do
not support the inhome testing of OSA patients.
Many pts are diagnosed and treated fo   More...

Home sleep studies, unattended, either for
diagnostic or therapeutic purposes, is a bad
idea. Issues include poor quality, long term
compliance, high long term cost, poor mask fit,
and inability to add oxygen during these
stud   More...

Dear Sirs,

As a health care provider (RRT, RPSGT) in a Sleep
Disorders Center, I see first hand the problems
associated with patients who have had home
screening studies. The data received is only a
guide and does not provi   More...

I am against Medicare/Medicaid reopening the issue of home monitoring. I believe this is a typical insurance company move to obtain the cheapest way of providing service to sleep patients. Laboratory monitoring has been proven over the    More...

I THINK THE DECISION TO INCLUDE PORTABLE MULTI CHANNEL HOME SLEEP TESTING DEVICES WOULD BE A
BENEFIT,NOT ONLY TO THE PATIENT,BUT A COST SAVINGS FOR MEDICARE AND MEDICAID.AS AN RT IN THE HOMECARE FIELD,I EVALUATE HOMEBOUND PATIENT   More...

Sleep medicine is very complex and often
confusing. Cutting corners in diagnosis can lead
to poor results. Some patients are obvious as
sick with obstructive sleep apnea, but even these
can have more than one sleep diagnosis. Th   More...

I am a registered respiratory therapist with 30
plus years of experience in the field. I have 15
year experience with treating sleep related
disorders. I have served as an expert witness for
Social Security Administration disablity   More...

Patients with cardiac and lung issues need to be
monitored by a technician at least the first time
CPAP is attempted, otherwise central apneas could
occur from the titration and that would be
dangerous to the patient's health.
<   More...

Leslie V. Norwalk, Esq.
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

<   More...

At-home sleep testing for obstructive sleep apnea
(OSA) is an important diagnostic tool for a
condition that is highly prevalent, serious, and
easily treated.

The clinical information obtained from ambulatory
testing is valu   More...

I am strongly against in home testing for
Obstructive Sleep Apnea. Sleep Disorders are not
just black and white open and shut cases. Each
patient is different and deserve a treatment
tailored toward there problem. Also many patient   More...

Home sleep studies do increase access to a sleep
study as long as there are individuals who can
apply the sensors and be available when there is
a malfunction of the sensor. The sleep "centers"
would still have to have multiple equ   More...

My concern relates to the approval of in-home Polysomnology studies. I believe that the quality of care will decrease, the observed monitoring for PLM or arm motion will be inadequate, and in whole the data provided of
a lesser q   More...

Dear CMS,

I think that the room for error, when
using the portable multi channel devices instead
of the facility based polysomnagrams, would be
enormous. There is no system out there right now
with the AI competent e   More...

I have worked with OSA patients for the last 20
years as far as providing CPAP and BiPAP therapy
through an HME company.

Each year I discover that we aren't even close to
reaching the untreated OSA population. Not only
th   More...

*Continuous Postitive Airway Pressure(CPAP)
Therapy for Obstructive Sleep Apnea(OSA)*

Before agreeing to allow in-home sleep studies,
a careful consideration of who should be allowed
to provide this type of service and what type   More...

There is great danger to patients in allowing
ambulatory studies to completely replace in-lab
monitored sleep studies. If this occurs, it will
increase the likelihood of misdiagnosis,
underdiagnosis and mismanagement of the health   More...

March 21, 2007

Steve Phurrough, MD
Director of Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

RE: National Coverage    More...

With the current extensive waiting time most
patients must endure in obtaining a sleep study
just to have obstructive sleep apnea diagnosed, I
feel that anything that can be done to expedite
the process should be attempted. With sl   More...

Home based monitoring will only work if a patient has apnea. There are currently 88 known sleep disorders. Home monitoring would not exclude most of the other sleep disorders. Research continues to provide new findings regarding sleep a   More...

I am writing in support of the issue of re-
working the way a patient would be qualified for
CPAP based on sleep testing. I have been in
respiratory care for 16 years now and have been
in home care for about 9 of those. I have been    More...

303 Catlin Street
Buffalo, MN 55313

Steve Phurrough, MD
Director of Coverage & Analysis Group
Center for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21   More...

In my opinion "In-home Obstructive Sleep Apnea
testing" should be covered by insurance.

I feel that polysomnography in the home, ie: an
unattended study should not be covered. The
validity and quality of the recording in the
home is substandard and does not accurately
reflect a true sleep/respiratory picture.
I hav   More...

Dr. Rollins,

I would like to submit a comment in favor of home
based qualification for OSA patients. As I am
sure you are aware CMS currently has a similar
process to qualify Oxygen patients that has been
used effectively.    More...

In the CMS review of indications and efficacy of
home testing, those conducting this review should
continue the diaglogue with the American Academy
of Sleep Medicine. This diaglogue would help
ensure that where authorized, the CM   More...

80% of the people with CHF have sleep disorders.
80% of the people who have had strokes have sleep
disorders.
45% of the people with hypertension have sleep
apnea.
50% of the adult males with diabetes have sleep
apnea.
We c   More...

Home Sleep Testing is one of many ways to use
emerging technologies to save us all money. More
people would agree to be tested in the home, the
overall expense would gradually come down due to
increased useage, further technologic    More...

I belieive that CMS should approve a concept similar to the over-night oximetry testing forhome oxygen. This type of testing would be more comfortable since this would be performed at home. This would also be less costly for CMS and ins   More...

Doing home sleep studies is an excellent idea.
Here in Alabama we are having to wait one month
or longer to get a sleep study done. Even with
documentation of desaturation by a pulse
oximeter we still have to get a sleep study done   More...

I am commenting in my capacity as the Regional Director of Sleep Disorders Centers for Minnesota Lung Center/Minnesota Sleep Institute. Over my many years working in sleep medicine, I have seen great advancements in technology that benefits patien   More...

This testing is very important and seems to get somewhat better results due to taking the test in the privacy of your own home.These units are very easy to work and are alot less stress on people who are already at their wits ends!

I am writing in support of coverage of sleep
studies available to patients at home , such as
with the FDA approved Itamar watch PAT
technology. Access to this technology would
would reduce costs associated with sleep labs
for s   More...

I believe that patients with dangerous sleep
disorders would have better acces to treatment,
insurers could save millions, respiratory
professionals could provide better patient care
if new technology was approved for coverage by <   More...

The American Association of Sleep Technologists
(AAST) is the professional organization for the
sleep technology field, representing more than
3,000 sleep technologists and allied health care
providers. Sleep technologists have an   More...

I am a Respiratory Care Practitioner. Ten years ago I started a business in which we performed in home (ambulatory) sleep studies, using the NightWatch System. We provided all channels except the EEG leads, in place that data we could h   More...

Recently I discovered that the CMS is
entertaining the idea of changing the two hour
minimum time frame for determinng AHI for CPAP
coverage. I believe that by creating a distinct
score above the current AHI level and allowing
   More...

As a board certified Otolaryngologist since 1987
and board certified in Sleep Medicine since 1996,
my practice is devoted entirely to the treatment
of sleep disorders, in particular obstructive
sleep apnea.

1. I believe tha   More...

i believe it would be good to allwo in-home
sleep
testing

I think change should be reviewed in detail. If
the in home study will work and provide same or
similar results as a sleep lab study, this should
be an option made available. With the in home
option, I believe you will have a gre   More...

Dear CMS Investigators,

I am writing this letter to emphasize my
concerns about proposals to change the Centers
for Medicare & Medicaid Services national
coverage determination (NCD) regarding the
dia   More...

Hello.

I am the executive officer for the Respiratory Care Board of California. Our mandate is to protect the public from the unauthorized and/or unqualified practice of respiratory care. Sleep testing in the home would be valuable    More...

As a clinician, there is validity to testing in a
sleep lab. Even though patients may be more
comfortable at home, there is a lot that could go
wrong including: electrodes coming off or being
reapplied by the patient in the wrong p   More...

As a sleep technician for 15+ years all the information related to you in the request for reassessment can not be refuted, however, in my experience with several different types of ambulaory/home monitoring for OSA, this modality is not prefe   More...

Date: April 12, 2007

To: Center for Medicare and Medicaid
Services

From: Raul Pardo, MIA Diagnostics

Re: Public Comment re: Obstructive
Sleep Apnea Test (Ref. CAG-00093R2)

As president of MIA Diagnostics I w   More...

Unattended cardiopulmonary sleep studies should
not be used to prescribe cpap therapy for
patients with sleep apnea.There is no recording
of actual sleep with EEG leads leading to a host
of problems.
A)One can actually falsify a   More...

We believe that testing for obstructive sleep
apnea other than in an facility based sleep
study lab would likely result in inaccurate test
results and could leave many patients with OSA
undiagnosed and therefore left untreated for    More...

Re: AAO-HNS Request to include home monitoring in
NCD 240.4 for Continuous Positive Airway Pressure
(CPAP) Therapy for Obstructive Sleep Apnea (OSA)
(CAG-00093R2)


Dear CMS:

On behalf of the members of the American Th   More...

RE: CAG 00093R2

I am against the review of having in home patient evaluation for Obstructive Sleep Apnea (OSA) testing.

As a professional technologists with credentials in Polysomnography (RPSGT), I am against any and   More...

As a Sleep Professional who has been in this
field for over 20 years, I would like to state
my opposition to the ambulatory as opposed to
facility based Sleep testing. The equipment that
is utilized in the ambulatory testing is not   More...

Statement of the National Sleep Foundation

Regarding

CMS Review of the National Coverage
Determination Regarding the
Diagnosis of Patients with Obstructive Sleep
Apnea Requiring CPAP Therapy

The National Sleep Fou   More...

I support the use portable unattended sleep
studies. The technology provides for accurate and
dependable results. Cost savings as compared to
in-lab attented studies should be great.

Good Morning!

I wish to comment about using portable devices
for testing for OSA. I have been in management
for SLeep Labs for the past 10 years and what I
have been seeing is a increase in patients that
are very large. No   More...

For decades, sleep laboratories have served a
critical need in accurately diagnosing sleep
apnea. But, just as our world has changed
dramatically in other areas of technology, so
has the field of sleep apnea research and
diagn   More...

I am a respiratory therapist and department director of a respiratory therapy department that includes a 10 bed sleep lab. Home sleep studies to qualify for CPAP are not acceptable. This is not a controlled environment and there is no o   More...

I am highly in favor of allowing, and providing
coverage for, in home sleep testing for
obstructive sleep apnea. There are many devices
on the market that have been proven to correlate
highly with attended sleep testing and it woul   More...

Steve Phurrough, MD Director of Coverage & Analysis Group Center for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, Maryland 21244-1850

Re: Coverage of Home Sleep Testing

Dear Dr. Phurrough:

I a   More...

Date: 4/6/2007

TO: Centers for Medicare & Medicaid
Services

FROM: (Gerald A. Ruggiero M.S. RRT)

RE: Public Comment re: Obstructive
Sleep Apnea home testing (Ref: CAG-00093R2)

I am writing in my capacity as (d   More...

In home and mobile testing is often innaccurate
due to a lack of environmental controls. Patient's
homes have a large amount of electrical
interference which can skew the Polysomnogram. The
patients home may also be electrically unsafe   More...

I believe that the unattended sleep study is
reliable and accurate and should qualify for
reimbursement.

The proposal by the AAO-Head and Neck Surgery is
reminiscent of previous arguments by ENT
specialists and home care providers. The
argument remains whether home evaluation is
sufficient to identify patients with sleep
apnea/sl   More...

Medicare should not cover in home unattended sleep studies. A sleep study should be done in an accredited sleep lab attended by qualified staff to monitor.

Their proposal would open the flood gates of
fraud. CPAP use would expload across the country.

To Whom It May Concern:

While I am not a physician, I do have several
comments/questions regarding the current debate
on the alternatives of home testing as compared
to PSG. I do believe that home testing has a
valuable pla   More...

A few years ago, I used to perform in-home full
16 channel polysomnograms and CPAP titrations.
I had to repeat many tests because of EEG or
other leads which would become loose or fall off
during the night. I also had a problem w   More...

Home testing for the diagnosis of sleep disorders should not be acceptable to the CMS. Home studies cannot provide an environment which will ensure reliable results. Sleep studies require many parameters and a very controlled setting fo   More...

As Clinical Director and Community Outreach
Director of Delta Centers for Sleep, Ltd.
("Delta"), we file this comment in response to
the National Coverage Determination for
Obstructive Sleep Apnea ("OSA") submitted by the
Ameri   More...

April 10, 2007
Steve Phurrough, MD
Director of Coverage and Analysis Group
Centers for Medicaid and Medicare Services
7500 Security Boulevard
Baltimore, MD 21224-1850

Dear Dr. Phurrough:

Currently the CMS NCD - NCD for Continuous
Positive Airway Pressure (CPAP) Therapy For
Obstructive Sleep Apnea (OSA) (240.4)
States:
“The AHI is equal to the average number of
episodes of apnea and hypopnea per hour and must
   More...

You should be aware of recent literature that may
be helpful it making this decision. There will be
a new study published in the April issue of the
Canadian Respiratory Journal describing our
experience with empiric CPAP trial. In    More...

Home Sleep testing:

Underestimating the complexity of the technical
aspects of polysomnography can lead to hiring
inexperienced people who can be taught to
mechanically place electrodes and transducers on
patients. In an eff   More...

TESTING FOR OSA SOULD BE LEFT IN THE SLEEP LAB
SETTING! TO MANY THINGS CAN HAPPEN TO EFFECT THE
OUT COME OF THE TEST. A SUPERVISED STUDY SHOULD
BE ABLE TO ADDRESS ANY PROBLEMS THAT CAN OCCUR
THAT CAN GIVE A FALSE POITIVE READING FO   More...

I'm writing this in support of Medicare
maintaining the current policy of facility based
sleep studies, rather than home based studies.
A few comments need to be made about the
inaccuracies in the letter by the requestor.
Hom   More...

I am in favor of in-home OSA testing.As a RT
with 10 plus years in HME I have seen a long
backlog at all sleep facilities for patients to
get tested.Patients with severe OSA would have
better access to treatment and insurers could    More...

Date: 4/11/07

To: Centers for Medicare & Medicaid Services

From: Ralph E. Steele, MD, DABSM

RE: Public Comment re: Obstructive Sleep
Apnea home testing (Ref: CAG-00093R2)

It has come to my attention that certain med   More...

As a Respiratory Therapist and OSA patient I find
this a very personal subject. The heart of the
matter is access to care. How many patients do
will not or can not make it to a Sleep Lab? How
many loose their sense of urgency af   More...

This is in reference to OSA testing. My opinion is that at this time polysomnography testing should only be done in accred. institutes by licensed
respiratory therapist or registered polysomnograph tech. At this time e   More...

I think that sleep apnea testing should be
approved for in the home testing.

I feel home polysomnography testing of patients
would be good if it were monitored by a
Respiratory Therapist or a RPSGT and they stay
with that patient in their home. The patient
definately would benefit because it's his/her own    More...

I believe the current guidelines are very fair and if a full night is required to get a better picture and meet the guidelines, the patient can always come back. there are so many labs today with to many short cuts, to save time and mon   More...

I am currently running a clinical study using
home sleep tests to estimate the prevalence of
difficulties in anesthesia in patients with
sleep apnea. This study is not finished and I
cannot yet draw any true conclusions. However,   More...

I have worked in the field of sleep medicine for
10 years and am well aware of the ongoing debate
on the topic you are now considering. I was with
DigiTrace when we validated full in-home
unattended PSG (Dr. Fry et. al.). At Clev   More...

I do not believe in home monitoring is adequate
for the determination of sleep apnea. Having
performed sleep research including home
monitoring over the last 17 years, I have found
that these monitoring techniques frequently lead    More...

This a is a very good idea if you have the staff
to do all these on top of everything else RT's do.
What about pts. with no insurance coverage or no
income coming in at all, do they qualify. We have
sleep labs popping up everywhere    More...

IF home testing for OSA be approved I feel there
should be VERY strict & precise guidelines for
providers to follow in order to protect patients.
As a Respiratory Therapist and Registered Sleep
Technologist I have over 15 yrs exper   More...

I am a co-owner of a DME company in High Point,
NC that provides CPAP and related equipment to
patients diagnosed with sleep apnea, both OSA &
CSA. We provide no other DME- the treatment of
sleep apnea is our one and only business.   More...

April 12, 2007

Steve Phurrough, MD
Director of Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Re: National Coverage Dete   More...

Polysomnographic testing must be done in a
facility using trained polysomnographers. The
testing integrity is at risk due to hardware and
software issues the patient is not aware of and
can not fix. This also jeopardize   More...

I have been involved with the diagnosing and
treating of sleep disorders for 15 years. In that
time I have experience with home testing with
multichannel devices and with lab testing with
full polysomnography (including EEG). It is   More...

It is extremely important in this day and age of
more high tech equipment to make sure the results
your getting are viewed also by a professional
tech during testing for accuracy.

I urge CMS to continue the current CPAP coverage
policy in its present form.

I was one of the first physicians to be
Board-certified in sleep disorders medicine. Over
the years, many of us have worked hard to ensure
that the wa   More...

Dear Sir or Madam:

The request by the American Academy of
Otolaryngology ¨C Head and Neck Surgery to allow
portable, multi-channel home sleep testing as an
alternative to facility-based polysomnography in
the evaluation of o   More...