The public comment period for Medicare’s proposed national coverage determination (NCD) on noninvasive positive pressure ventilation (NIPPV) closes at the end of Thursday, April 10.
In an April 7 bulletin, the American Association for Homecare (AAHomecare) reminded providers that their experiences with respiratory patients can be impactful for policymakers.
“Your comments, with an emphasis on first-hand perspectives on the potential impacts of the proposed changes to patient care, are critical to making sure that CMS [Centers for Medicare & Medicaid Services] takes into account the real-world, practical impact the proposals will have on patients,” the organization said.
AAHomecare described proposed coverage criteria as “overly restrictive,” adding, “Burdensome administrative processes in the NCA [national coverage analysis] affect this chronically ill population.”
The organization’s main concerns with the proposed decision are as follows:
— The decision does not grandfather in patients already receiving RAD [respiratory assist devices] or HMV [home mechanical ventilators]. “Patients already relying on these devices are unlikely to have the documentation required by the draft NCD in their medical records,” AAHomecare said. “Moreover, if a physician/prescriber believes that the patient continues to benefit from the device, it would be inappropriate to remove the device from their home and risk hospitalization or death.”
— The decision would require patients to be re-evaluated every six months. This requirement “will make it even harder for chronically ill patients, especially those in rural areas, to access essential ventilation therapy,” AAHomecare said, adding that many patients would struggle to pay for the additional doctor visits.
— Arterial blood gas (ABG) testing would also be required every six months. AAHomecare called ABG testing “painful and invasive” for patients. Rural patients who don’t live near specialty medical facilities could again find it difficult to meet this requirement.
— The “five-hour” usage requirement is inconsistent with industry standards and policies. The proposed decision would require patients to use NIPPV for an average of five hours per day to remain compliant, but “The requirement is not consistent with current industry standards and policies, which define adherence to therapy as using PAP for ≥4 hours per night on 70% of nights during a consecutive 30-day period anytime during the first three months of initial usage.”
AAHomecare recommended that respiratory providers speak from their own experiences and expertise when sharing their comments with CMS. The association also has written an issue brief that can be used as a resource for comments and meetings.
“Timely noninvasive ventilation treatment is crucial in ensuring patients are receiving the care that they need to live,” the brief stated. “Peer-reviewed studies and an April 2025 Dobson/Davanzo/Health Economist study show the sooner a patient receives noninvasive ventilation treatment: (1) the lower the risk of death; (2) the less likely they are to be admitted to any inpatient setting; (3) the less likely they are to visit the emergency department; and (4) the lower the total Medicare spending.”
Share your comments with CMS by going to the public comments page and clicking on the “Submit Public Comment” button below the “Noninvasive Positive Pressure Ventilation in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD” title.
