Proposed LCD for Polysomnography in NC,SC,VA, WV

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Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Sat Mar 12, 2016 10:43 pm

In public comments until March 24, 2016
PROPOSED/DRAFT Local Coverage Determination (LCD):
Polysomnography (DL36593)
Policy adds PLMS/RLS and Respiratory disorders as indications

Limits techs credentials, but adds RST
1. Registered Polysomnography Technologist (RPSGT)
2. Registered Electroencephalographic technologist (R. EEG T.) – Polysomnography
3. Certified Respiratory Therapist -Sleep Disorders Specialist (CRT-SDS)
4. Registered Respiratory Therapist -Sleep Disorders Specialist (RRT-SDS)
5. American Board of Sleep Medicine Registered Sleep Technologist (RST)

and tightens sleep facilities

The sleep center or laboratory must maintain documentation on file that indicates it is accredited by the American Academy of Sleep Medicine (AASM), Accreditation Commission for Health Care (ACHC), or that it is accredited as a sleep laboratory by the Joint Commission. If the Joint Commission survey of the general hospital accreditation includes the hospital-based sleep lab, an additional accreditation is not needed. This documentation must be available on request. The AASM, ACHC, or Joint Commission accreditation applies to the hospital and freestanding facilities (including sleep clinics that are part of a physician’s office, and all other non-hospital-based facilities where sleep studies are performed. Diagnostic testing performed in an Independent Diagnostic Testing Facility (IDTF) must follow the supervision and credentialing guidelines set forth by CMS and/or Palmetto GBA.



Interesting changes proposed. Some good, but will disenfranchise RT's without SDS. Is there a sub specialty certification in polysomnography for R.EEG.T?
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Sat Mar 12, 2016 10:44 pm

Bolding is mine BTW
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby RPSGT2000something » Wed Mar 16, 2016 3:31 am

This is scary news for a lot of labs and sleep techs. I'm surprised no one has commented yet. Does "proposed LCD" mean that it might not pass?
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Thu Mar 17, 2016 9:17 pm

No- it means they are revising it. Their stated rational for the proposed draft "Creation of Uniform LCDs Within a MAC Jurisdiction" ,
so it will be revised. Based on public comments that are now being made some language may be altered from original draft, but the revision will probably take place.
How quickly, I don't know.
There are several changes then the ones I highlighted. They opened medical conditions for testing to include RLS/PLMS and respiratory disorders, which they go on to identify criteria. Originally, they only had 3 medicals conditions that warranted testing, sleep apnea, narcolepsy and parasomnia. Now they list 5.
Whats also interesting is what is written under Utilization Guidelines "Generally, a maximum of three "sleep naps" is adequate to diagnose narcolepsy.


"http://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36592&ver=7
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby somnonaut » Thu Mar 17, 2016 10:20 pm

There is no cost savings performing 3 naps versus 5.
Interesting on the included medical conditions. May give Insomnia an avenue for PSG exploration.
Found this from 2013 today.
http://oig.hhs.gov/oei/reports/oei-05-12-00340.pdf
Department of Health and Human Services
OFFICE OF INSPECTOR GENERAL
QUESTIONABLE BILLING FOR POLYSOMNOGRAPHY SERVICES
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Fri Mar 18, 2016 9:38 pm

Yeah, I read the OIG report a few years ago. I review every order and send it back if it doesn't meet CMS criteria.
I request the clinical note also at the time of the order. If the note doesn't meet CMS criteria, I send that back.
Sometimes it's multiple attempts to get the criteria met. I am still amazed at providers who send an order and there is no mention of anything related to sleep apnea or any diagnosis that supports sleep testing. Yet the order will be marked with the right signs and symptoms and they'll put down some other wacky diagnosis.
We really need to start a clinic. Been working on it for 2 years now.

Do not see indication for polysomnogram with insomnia, unless it is associated with signs and symptoms of sleep apnea.
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby RPSGT2000something » Thu May 05, 2016 4:42 pm

respbarb wrote:In public comments until March 24, 2016
PROPOSED/DRAFT Local Coverage Determination (LCD):
Polysomnography (DL36593)
Policy adds PLMS/RLS and Respiratory disorders as indications

Limits techs credentials, but adds RST
1. Registered Polysomnography Technologist (RPSGT)
2. Registered Electroencephalographic technologist (R. EEG T.) – Polysomnography
3. Certified Respiratory Therapist -Sleep Disorders Specialist (CRT-SDS)
4. Registered Respiratory Therapist -Sleep Disorders Specialist (RRT-SDS)
5. American Board of Sleep Medicine Registered Sleep Technologist (RST)

and tightens sleep facilities

The sleep center or laboratory must maintain documentation on file that indicates it is accredited by the American Academy of Sleep Medicine (AASM), Accreditation Commission for Health Care (ACHC), or that it is accredited as a sleep laboratory by the Joint Commission. If the Joint Commission survey of the general hospital accreditation includes the hospital-based sleep lab, an additional accreditation is not needed. This documentation must be available on request. The AASM, ACHC, or Joint Commission accreditation applies to the hospital and freestanding facilities (including sleep clinics that are part of a physician’s office, and all other non-hospital-based facilities where sleep studies are performed. Diagnostic testing performed in an Independent Diagnostic Testing Facility (IDTF) must follow the supervision and credentialing guidelines set forth by CMS and/or Palmetto GBA.



Interesting changes proposed. Some good, but will disenfranchise RT's without SDS. Is there a sub specialty certification in polysomnography for R.EEG.T?


Have you heard anything about when this is supposed to pass? I'm sitting here thinking about all the unregistered techs I know who aren't even trying to get registered ...
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Thu May 05, 2016 9:04 pm

Yes- effective date is June 13, 2016
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby RPSGT2000something » Fri May 06, 2016 9:47 am

Thank you. Would you happen to have a link where it states the effective date? I've searched and can't find it.
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Fri May 06, 2016 9:43 pm

Do you know how to navigate LCD's on CMS website? It's listed under future LCD for our jurisdiction.
I attached the file in pdf
Attachments
Local Coverage Determination for Polysomnography (L36593).pdf
Future LCD polysomnography
(239.34 KiB) Downloaded 56 times
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby RPSGT2000something » Sat May 07, 2016 2:31 am

I don't but am trying to learn. Thank you very much, Respbarb. This new law is very concerning to me as I've got many friends/coworkers that are going to be out of a job and even my boss isn't taking it seriously.
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Re: Proposed LCD for Polysomnography in NC,SC,VA, WV

Postby respbarb » Sun May 08, 2016 3:32 am

Well, not taking CMS seriously is a big mistake. It is not a law. It is a local coverage determination for pts. with Medicare/Medicaid coverage in our MAC jurisdiction. Our carrier, Palmetto is a CMS carrier and can set criteria that is stricter than the NCD ( national coverage determination) just not more lax.
When you put in for reimbursement on a claim, you are saying that you meet the criteria. When you accept payment and haven't met criteria you are in essence committing fraud.
Not a smart thing to do. May not get caught, but if you do it can be bad.And can affect your Medicare provider ID. If you lose that, most places are out of business, because they cannot survive without CMS patients.
If criminal charges come with it, you can be barred from ever accepting a federal dollar again.
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