WASHINGTON – Several leading healthcare organizations, including AAHomecare, the COPD Foundation, the Council for Quality Respiratory Care, and VGM Government Relations, have urged the Centers for Medicare and Medicaid Services (CMS) to establish a clear implementation timeline for the new national coverage determination (NCD) on non-invasive positive pressure ventilation (NIPPV).
In a joint letter sent on July 23, the groups requested that CMS delay implementation of the NCD—published on June 9—by at least one year to allow for an orderly transition.
“A well-defined implementation glidepath would help prevent unintended disruptions in access to life-sustaining respiratory assist devices (RADs) and home mechanical ventilators (HMVs) for Medicare and Medicare Advantage beneficiaries,” the letter states.
Why a Phased Rollout Is Essential
The groups highlighted several reasons for requesting a delay:
- Policy clarity: Despite the new NCD, significant ambiguities remain. Further guidance is needed to ensure consistent understanding and application across providers.
- Education & training: Time is needed to inform and train physicians, respiratory therapists, and patients about the new requirements.
- Technology updates: Manufacturers must revise hardware and software to meet new standards; providers will need time to adapt their compliance and billing systems.
- Monitoring burden: The expanded documentation and tracking requirements could significantly increase workload for both suppliers and patients.
- Access to testing: New arterial blood gas (ABG) testing rules may limit access, especially in outpatient settings with limited resources.
Ensuring Consistency Across Medicare
The letter also emphasized the importance of applying any timeline uniformly across both Medicare fee-for-service and Medicare Advantage plans.
“We’re ready to provide further input, but hope this summary enables CMS to work collaboratively with the community,” the letter concludes. “Without appropriate access to RADs and HMVs, patients could face increased hospitalizations, higher Medicare costs, and a diminished quality of life.”
