WASHINGTON, D.C. – As the industry continues to review the impact of the updated National Coverage Determination (NCD) for Noninvasive Positive Pressure Ventilation (NIPPV) in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD, AAHomecare is actively engaged with member companies and allied HME stakeholders to ensure a transition process that minimizes disruption and protects patient access.

We thank CMS for incorporating several important clarifications and improvements in the final NCD that were submitted by the industry during the comment period. We recognize, however, the operational challenges the final NCD will present for NIV suppliers. From system updates to new adherence requirements, implementing new coverage criteria of this scope will require significant coordination.

To help ensure suppliers’ voices are heard during this critical time, AAHomecare is working closely with partners including CQRC and VGM to identify areas where additional clarity, resources, or support may be needed, and to communicate our concerns with CMS and other policymakers. We appreciate the engagement of stakeholders across the industry who are bringing valuable insight and energy to this ongoing effort.

We will continue to work with CMS and its contractors to minimize disruption for patients and providers in implementing the new coverage criteria. As part of that effort, we urge CMS to allow for a 12-month implementation period to enable stakeholders to adapt systems, update workflows, and conduct necessary training to support compliance with the final policy.

The Regulatory Council will be meeting next week to review the changes and outline the industry’s next steps. Updates and analysis will be shared with membership as this work progresses.

Finally, we appreciate the strong industry response in providing comments on the NCD. Your thoughtful comments, backed by data and direct experience serving patients, helped deliver significant improvements over the initial proposal.