INDUSTRY URGES CMS TO SET CLEAR TIMELINE FOR NIPPV COVERAGE CHANGES 

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WASHINGTON – Four major health care organizations—AAHomecare, the COPD Foundation, the Council for Quality Respiratory Care, and VGM Government Relations—have formally requested that the Centers for Medicare & Medicaid Services (CMS) establish a clear implementation timeline for the new national coverage determination (NCD) for non-invasive positive pressure ventilation (NIPPV). 

In a letter sent July 23, the groups asked CMS to delay implementation until at least one year after the NCD’s publication date of June 9. 

“Adopting a clear implementation glidepath will allow the Trump administration to avoid the unintended consequence of Medicare beneficiaries and Medicare Advantage enrollees losing access to or not being able to access life-sustaining respiratory assist devices (RADs) and home mechanical ventilators (HMVs) under the new NIPPV NCD,” the letter states. 

Why a glidepath is needed 

The groups outlined several reasons for a phased approach: 

  • Policy clarity: While the NCD addresses coverage for RADs and HMVs, many details remain unclear. Additional guidance is needed to ensure prescribers, suppliers and other stakeholders have a consistent understanding of the new requirements. 
  • Education & training: Once the policies are clarified, the community will need time to educate physicians, respiratory therapists and patients—many of whom may be unaware of the changes. 
  • Technology updates: Manufacturers must update hardware and software to meet new standards. Providers will then need time to align their compliance and billing systems accordingly. 
  • Monitoring burden: The new tracking requirements will significantly increase the workload for suppliers and patients. Encouraging compliance is already challenging; enforcing it will be even more complex. 
  • Access to testing: New arterial blood gas (ABG) testing requirements may limit access, especially in areas where such tests are not readily available in outpatient settings. 

Call for consistency across Medicare 

In the letter, the groups also emphasized that any implementation date should apply uniformly to both Medicare fee-for-service and Medicare Advantage claims. 

“We would welcome the opportunity to provide more detail but hope that this overview allows CMS to work with the community to protect patients who need these devices from unintentionally losing access to them or not being able to access them when needed,” the letter continues. “The lack of access to RAD and HMV will result in higher hospitalization rates and substantially higher Medicare costs, as well as lead to a lower quality of life for those patients who medically require these devices.”