Optimal NIV Medicare access promotion – a hopeful way forward for users of NIV

Use of positive airway pressure (PAP) devices for treatment of sleep apnea was first described in 1981. Subsequent use of PAP devices expanded to treat patients with respiratory failure. While the treatment in this population has rapidly gained widespread use and undoubtedly has reduced morbidity and mortality in these populations, policies governing these prescriptions have not really kept up with the burgeoning need.

In 2020, Drs. Peter Gay and Robert Owens brought together a technical expert panel (TEP) to systematically review the CMS policies with an eye to remove “regulatory barriers” to improve access for these patients with the mantra: “the right device gets to the right patient at the right time.”

The panel focused on “Optimal NIV Medicare Access Promotion (ONMAP),” and members with specific expertise were recruited for five patient groups: Thoracic Restrictive Disorders (TRD), COPD, Central Sleep Apnea (CSA), Hypoventilation Syndromes (HVS), and Obstructive Sleep Apnea (OSA). Each group reviewed the current coverage, outlined the deficiencies, and suggested revisions. Herein, I will briefly highlight each group’s most important points.
 

TRD: The goal for this group was to bring the US standards of care closer to the rest of the world. This group advocates that the start of noninvasive ventilation (NIV) should be substantially earlier, to provide the largest improvement in disease outcome and stability. Other prominent features submitted included arterial blood gases (ABG) to not be the only form of CO₂ measurement allowed; paying for a second device if patients are using NIV continuously; qualification for a BiPAP to include if vital capacity is ≤ 80%; and, to obtain a home mechanical ventilator, a patient must either fail BiPAP or have extreme loss of function, high pressure requirements, or need mouthpiece ventilation.

CSA: The big challenges with this diagnosis related to qualifying coverage language in the current policies, which are confusing for many providers. Additionally, these policies often deny certain PAP devices and/or oxygen therapy. The group proposed: a single definition of CSA; eliminate discussion of hypoventilation; mirror qualifying symptoms, and, continuing coverage, to the same as that for OSA treatment; and remove need for a prior failure of BiPAP without a backup rate (BUR). The group also had specific recommendations for when oxygen therapy should be covered in patients with CSA.

COPD: This group also focused on the oxygen therapy and promoting use of devices with a BUR. Two problematic areas included the requirement that nocturnal oxygen saturation must drop to ≤ 88% for at least 5 cumulative minutes, and, that patients must begin with an S mode device (no BUR) for at least 2 months and can only then be prescribed a device with a BUR if CO₂ fails to drop. The group advocates for the removal of both, the need for a nocturnal oximetry test, and, to “try” an S mode device. The panel advocated giving the prescribing physician discretion in making this determination. The panel also provided recommendations on when a home mechanical ventilator (HMV) should be considered instead of BiPAP therapy.

HVS: Hypoventilation syndromes are a heterogeneous group of disorders with hypercapnia, defined as a Paco₂ ≥45 mm Hg. This panel noted that the current coverage criteria are outdated and fail to recognize the spectrum of disease severity and advances in technology, which often leads to circumvention by prescribing more costly home mechanical ventilators (HMV). Consistent with the TRD group, this panel recommended acceptance of surrogate noninvasive end tidal and transcutaneous Pco₂ and venous blood gases in lieu of arterial blood gases. Additionally, they suggested no longer requiring CO₂ measures while using prescribed oxygen; eliminating the need for a sleep study to avoid delays in care for patients being discharged from the hospital; removing spirometry as a requirement; and no longer a failure of BiPAP without a BUR.

OSA: The initial purpose of examining OSA in this process was to examine when BiPAP should be utilized for treatment; however, it necessitated examination of the entire policy for PAP. The areas that were identified as needing revision included: expansion of the symptom list for patients with OSA; revising the “4 hour rule,” suggesting that 2 hours has been proven to provide benefit; eliminating the need for another sleep study to re-qualify for PAP or supplemental oxygen; and embracing telehealth as a way to improve accessibility for follow-up visits.

For details, please review the papers published in the November 2021 issue of the journal CHEST^® (2021; 160[5]:1579-1990, e377-e543).

We now await what CMS will do with our recommendations and work for “the right device to the right patient at the right time.”

Acknowledgment: Drs. Gerald Criner, Nicholas Hill, Babak Mohklesi, Timothy Morgenthaler, and Lisa Wolfe assisted with the content.

Use of positive airway pressure (PAP) devices for treatment of sleep apnea was first described in 1981. Subsequent use of PAP devices expanded to treat patients with respiratory failure. While the treatment in this population has rapidly gained widespread use and undoubtedly has reduced morbidity and mortality in these populations, policies governing these prescriptions have not really kept up with the burgeoning need.

In 2020, Drs. Peter Gay and Robert Owens brought together a technical expert panel (TEP) to systematically review the CMS policies with an eye to remove “regulatory barriers” to improve access for these patients with the mantra: “the right device gets to the right patient at the right time.”

The panel focused on “Optimal NIV Medicare Access Promotion (ONMAP),” and members with specific expertise were recruited for five patient groups: Thoracic Restrictive Disorders (TRD), COPD, Central Sleep Apnea (CSA), Hypoventilation Syndromes (HVS), and Obstructive Sleep Apnea (OSA). Each group reviewed the current coverage, outlined the deficiencies, and suggested revisions. Herein, I will briefly highlight each group’s most important points.
 

TRD: The goal for this group was to bring the US standards of care closer to the rest of the world. This group advocates that the start of noninvasive ventilation (NIV) should be substantially earlier, to provide the largest improvement in disease outcome and stability. Other prominent features submitted included arterial blood gases (ABG) to not be the only form of CO₂ measurement allowed; paying for a second device if patients are using NIV continuously; qualification for a BiPAP to include if vital capacity is ≤ 80%; and, to obtain a home mechanical ventilator, a patient must either fail BiPAP or have extreme loss of function, high pressure requirements, or need mouthpiece ventilation.

CSA: The big challenges with this diagnosis related to qualifying coverage language in the current policies, which are confusing for many providers. Additionally, these policies often deny certain PAP devices and/or oxygen therapy. The group proposed: a single definition of CSA; eliminate discussion of hypoventilation; mirror qualifying symptoms, and, continuing coverage, to the same as that for OSA treatment; and remove need for a prior failure of BiPAP without a backup rate (BUR). The group also had specific recommendations for when oxygen therapy should be covered in patients with CSA.

COPD: This group also focused on the oxygen therapy and promoting use of devices with a BUR. Two problematic areas included the requirement that nocturnal oxygen saturation must drop to ≤ 88% for at least 5 cumulative minutes, and, that patients must begin with an S mode device (no BUR) for at least 2 months and can only then be prescribed a device with a BUR if CO₂ fails to drop. The group advocates for the removal of both, the need for a nocturnal oximetry test, and, to “try” an S mode device. The panel advocated giving the prescribing physician discretion in making this determination. The panel also provided recommendations on when a home mechanical ventilator (HMV) should be considered instead of BiPAP therapy.

HVS: Hypoventilation syndromes are a heterogeneous group of disorders with hypercapnia, defined as a Paco₂ ≥45 mm Hg. This panel noted that the current coverage criteria are outdated and fail to recognize the spectrum of disease severity and advances in technology, which often leads to circumvention by prescribing more costly home mechanical ventilators (HMV). Consistent with the TRD group, this panel recommended acceptance of surrogate noninvasive end tidal and transcutaneous Pco₂ and venous blood gases in lieu of arterial blood gases. Additionally, they suggested no longer requiring CO₂ measures while using prescribed oxygen; eliminating the need for a sleep study to avoid delays in care for patients being discharged from the hospital; removing spirometry as a requirement; and no longer a failure of BiPAP without a BUR.

OSA: The initial purpose of examining OSA in this process was to examine when BiPAP should be utilized for treatment; however, it necessitated examination of the entire policy for PAP. The areas that were identified as needing revision included: expansion of the symptom list for patients with OSA; revising the “4 hour rule,” suggesting that 2 hours has been proven to provide benefit; eliminating the need for another sleep study to re-qualify for PAP or supplemental oxygen; and embracing telehealth as a way to improve accessibility for follow-up visits.

For details, please review the papers published in the November 2021 issue of the journal CHEST^® (2021; 160[5]:1579-1990, e377-e543).

We now await what CMS will do with our recommendations and work for “the right device to the right patient at the right time.”

Acknowledgment: Drs. Gerald Criner, Nicholas Hill, Babak Mohklesi, Timothy Morgenthaler, and Lisa Wolfe assisted with the content.

Use of positive airway pressure (PAP) devices for treatment of sleep apnea was first described in 1981. Subsequent use of PAP devices expanded to treat patients with respiratory failure. While the treatment in this population has rapidly gained widespread use and undoubtedly has reduced morbidity and mortality in these populations, policies governing these prescriptions have not really kept up with the burgeoning need.

In 2020, Drs. Peter Gay and Robert Owens brought together a technical expert panel (TEP) to systematically review the CMS policies with an eye to remove “regulatory barriers” to improve access for these patients with the mantra: “the right device gets to the right patient at the right time.”

The panel focused on “Optimal NIV Medicare Access Promotion (ONMAP),” and members with specific expertise were recruited for five patient groups: Thoracic Restrictive Disorders (TRD), COPD, Central Sleep Apnea (CSA), Hypoventilation Syndromes (HVS), and Obstructive Sleep Apnea (OSA). Each group reviewed the current coverage, outlined the deficiencies, and suggested revisions. Herein, I will briefly highlight each group’s most important points.
 

TRD: The goal for this group was to bring the US standards of care closer to the rest of the world. This group advocates that the start of noninvasive ventilation (NIV) should be substantially earlier, to provide the largest improvement in disease outcome and stability. Other prominent features submitted included arterial blood gases (ABG) to not be the only form of CO₂ measurement allowed; paying for a second device if patients are using NIV continuously; qualification for a BiPAP to include if vital capacity is ≤ 80%; and, to obtain a home mechanical ventilator, a patient must either fail BiPAP or have extreme loss of function, high pressure requirements, or need mouthpiece ventilation.

CSA: The big challenges with this diagnosis related to qualifying coverage language in the current policies, which are confusing for many providers. Additionally, these policies often deny certain PAP devices and/or oxygen therapy. The group proposed: a single definition of CSA; eliminate discussion of hypoventilation; mirror qualifying symptoms, and, continuing coverage, to the same as that for OSA treatment; and remove need for a prior failure of BiPAP without a backup rate (BUR). The group also had specific recommendations for when oxygen therapy should be covered in patients with CSA.

COPD: This group also focused on the oxygen therapy and promoting use of devices with a BUR. Two problematic areas included the requirement that nocturnal oxygen saturation must drop to ≤ 88% for at least 5 cumulative minutes, and, that patients must begin with an S mode device (no BUR) for at least 2 months and can only then be prescribed a device with a BUR if CO₂ fails to drop. The group advocates for the removal of both, the need for a nocturnal oximetry test, and, to “try” an S mode device. The panel advocated giving the prescribing physician discretion in making this determination. The panel also provided recommendations on when a home mechanical ventilator (HMV) should be considered instead of BiPAP therapy.

HVS: Hypoventilation syndromes are a heterogeneous group of disorders with hypercapnia, defined as a Paco₂ ≥45 mm Hg. This panel noted that the current coverage criteria are outdated and fail to recognize the spectrum of disease severity and advances in technology, which often leads to circumvention by prescribing more costly home mechanical ventilators (HMV). Consistent with the TRD group, this panel recommended acceptance of surrogate noninvasive end tidal and transcutaneous Pco₂ and venous blood gases in lieu of arterial blood gases. Additionally, they suggested no longer requiring CO₂ measures while using prescribed oxygen; eliminating the need for a sleep study to avoid delays in care for patients being discharged from the hospital; removing spirometry as a requirement; and no longer a failure of BiPAP without a BUR.

OSA: The initial purpose of examining OSA in this process was to examine when BiPAP should be utilized for treatment; however, it necessitated examination of the entire policy for PAP. The areas that were identified as needing revision included: expansion of the symptom list for patients with OSA; revising the “4 hour rule,” suggesting that 2 hours has been proven to provide benefit; eliminating the need for another sleep study to re-qualify for PAP or supplemental oxygen; and embracing telehealth as a way to improve accessibility for follow-up visits.

For details, please review the papers published in the November 2021 issue of the journal CHEST^® (2021; 160[5]:1579-1990, e377-e543).

We now await what CMS will do with our recommendations and work for “the right device to the right patient at the right time.”

Acknowledgment: Drs. Gerald Criner, Nicholas Hill, Babak Mohklesi, Timothy Morgenthaler, and Lisa Wolfe assisted with the content.