WASHINGTON, D.C. – Following the release of the final National Coverage Determination (NCD) for non-invasive positive pressure ventilation (NIPPV) on June 9, AAHomecare has launched a coordinated effort to support our members through the transition and advocate for a realistic path forward with implementing the new policy changes.

We appreciate that CMS incorporated several improvements and clarifications in the final policy sought by AAHomecare and HME stakeholders, including:

• Clarifying that the new policies will not apply to patients who already rely on RADs or HMVs to ensure continuity of care.
• Expressly stating that the NCD policy should not be used as a justification for step-therapy that could force patients onto a device that a physician knows is not appropriate for that patient.
• Clarification that an ABG is not required for re-evaluations.
• Clarification that re-evaluation is required twice for only the first year.
• Removed the requirement that the patient or caretaker can physically use the device.
• Clarified that a formal sleep study is not required to determine OSA is not the primary cause of chronic respiratory failure.
• Changed the usage requirement from 5 hours to 4 hours a day for 70% of the time

However, there are significant operational concerns raised by the updated NCD. As part of our immediate follow-up, AAHomecare’s leadership councils are actively reviewing the final policy language and identifying areas that require additional clarification.

Engaging CMS and Capitol Hill
AAHomecare quickly set a meeting with CMS on June 17, sharing concerns about how new requirements would impact operations and patient care. In this meeting, we requested a transitional period of one year that would allow suppliers, prescribers, and manufacturers time to implement the significant changes required by the new NCD while maintaining uninterrupted patient care. We also discussed the need to ensure a reasonable transition period in meetings with legislators and staff on Capitol Hill last week.

In addition, AAHomecare is pulling together questions developed by the DME MAC Councils and our internal workgroups to share with CMS and contractors. These questions will be aimed at clarifying new requirements and timelines.

We are committed to elevating DMEPOS industry concerns in ongoing discussions with CMS and contractors and will continue to push for an implementation approach that reflects the realities of prescriber and supplier operations today. We will keep members informed on clarifications and updates as they are released.