ARLINGTON, Virginia—The American Association for Homecare (AAHomecare) strongly encouraged respiratory suppliers to comment on a proposed National Coverage Determination (NCD) on noninvasive positive pressure ventilation (NIPPV). Comments are due Thursday, Apr. 10 (11:59 p.m. ET).
"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 the Centers for Medicare & Medicaid Services (CMS) takes into account the real-world practical impact the proposals will have on patients," AAHomecare said in a release.
AAHomecare provided messaging for comments below, along with new resources available.
"Below are key messages you can include in your comments on how the overly restrictive coverage criteria and burdensome administrative processes in the NCA affect this chronically ill population," AAHomecare said. "Please reframe in your own words and draw on your own experiences with NIPPV patients to have the strongest impact."
Key Messages for Your Comments
- Concern that there is no grandfathering of patients already receiving RAD or HMV therapies: Patients already relying on these devices are unlikely to have the documentation required by the draft NCD in their medical records. 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.
- Concern with the 6-month re-evaluation and its impact on continued therapy: The proposed six-month requirement will make it even harder for chronically ill patients, especially those in rural areas, to access essential ventilation therapy. Many patients already struggle to see their doctors annually, and more frequent visits will create additional barriers to care. Many patients may not have the financial ability to cover the cost-sharing required by these additional visits. This could lead to delays or disruptions in critical treatment, worsening health outcomes.
- Concern with the requirement that a repeat Arterial Blood Gas (ABG) is obtained every six months as part of the re-evaluation: Strict qualifying criteria, such as requiring a painful and invasive ABG draw, are unnecessary and burdensome for this chronically ill patient population. Excluding the use of other reliable and less invasive tests like VBG or ETCO₂ will further limit access to care, particularly in rural areas lacking specialty facilities.
- Concern with the requirement for a patient to utilize the therapy on average five hours per day: The requirement is not consistent with current industry standards and policies which define adherence to therapy as using PAP for greater than or equal to four hours per night on 70% of nights during a consecutive thirty day period anytime during the first three (3) months of initial usage. The implementation of a new measure has the potential to disrupt patient care, especially considering the complexities of adoption that will be faced by suppliers and device manufacturers.
Do not feel obligated to comment on every one of these points; focus on the ones you know best. More tips on submitting effective comments can be found here.
Submitting Your Comments
To submit your comments, you will need to click the ‘Submit Public Comment’ blue button toward the top of the NIPPV Proposed Decision Memo posting page. From there, you will be led to a comment submission page where you will copy and paste your comments into the online form.
Additional Resources Available
- Issue Brief: AAHomecare is working to raise awareness of the potential impacts of the proposed NCD with members of Congress. See the NIPPV Issue Brief, it developed for its meetings on Capitol Hill for more messaging/language ideas
- New Study Available: Timely noninvasive ventilation treatment is crucial in ensuring patients are receiving the care that they need to live. A new study from health economics and policy consult 2025 Dobson/Davanzo study shows:
- 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 visits; and (4) the lower the total Medicare spending.
- See Impact of Non-Invasive Ventilator at Home (NIVH billed under HCPCS E0466) on Select Outcomes for Medicare Fee-for-Service (FFS) Beneficiaries for details and additional perspective.