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Back to Noninvasive Positive Pressure Ventilation (NIPPV) in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD Tracking Sheet

National Coverage Analysis (NCA) View Public Comments

Noninvasive Positive Pressure Ventilation (NIPPV) in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD

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Total Comments: 5

Commenter	Comment Information
Reid, Monty	Title: RRT Organization: Total Respiratory Date: 09/16/2024 Comment: Having worked for over 45 years in the field of Respiratory Care, I have setup and managed over 1000 non-invasive ventilators and have seen the vast majority of compliant patients benefit greatly from the benefits provided. As a diagnosis driven modality, requirements need to be clear cut and adhered to by both DMEs and insurers. This should be across the board with all variations of Medicare required to follow. This includes Red, White and Blue AND Medicare Advantage plans. Chronic respiratory conditions account for inordinately large costs for hospitalizations and unscheduled physician visits, both of which are proven to be reduced by compliant use of NIV in conjunction with proper medication management and early intervention. Less Having worked for over 45 years in the field of Respiratory Care, I have setup and managed over 1000 non-invasive ventilators and have seen the vast majority of compliant patients benefit greatly from the benefits provided. As a diagnosis driven modality, requirements need to be clear cut and adhered to by both DMEs and insurers. This should be across the board with all variations of Medicare required to follow. This includes Red, White and Blue AND Medicare Advantage plans. Chronic More
makou, davon	Title: good Organization: good Date: 09/12/2024 Comment: good1
Mort, Marisa	Title: A/R Manager Organization: Total Respiratory and Rehab Date: 09/12/2024 Comment: I appreciate that this topic is being considered as a new NCD section, however I feel strongly that other conditions need to be considered for NCD coverage as well that constitute the need for NIPPV usage in the home. There should be clinical coverage guidelines for providers to follow for neuromuscular conditions and thoracic restrictive conditions. Often times, there is a fine line of what diagnosis should be considered as "thoracic restrictive", as many providers can consider obesity hypoventilation syndrome restrictive. There needs to be a list of qualifying covered and or noncovered diagnoses for NIPPV usage in the home. There should be lists of tests and value that are qualifying for NIPPV coverage. There also needs to be clarification on compliant usage for NIPPV, as often times the RAD guidelines intermix for ventilators however, ventilators do not have specific rulesets to follow and this makes it very difficult for providers to be certain if all documentation requirements are met in the case of an audit. There should also be a strong ruleset for the Medicare Advantage plans to follow, as a majority of them are NOT following CMS guidelines, but are following the RAD guidelines when determining vent qualifications. Not having an NCD or LCD's for NIPPV has done a huge disservice to both beneficiaries and providers. Less I appreciate that this topic is being considered as a new NCD section, however I feel strongly that other conditions need to be considered for NCD coverage as well that constitute the need for NIPPV usage in the home. There should be clinical coverage guidelines for providers to follow for neuromuscular conditions and thoracic restrictive conditions. Often times, there is a fine line of what diagnosis should be considered as "thoracic restrictive", as many providers can consider obesity More
Renner-Smith, Teresa	Title: Quality System Analyst, LRCP, PLMHP, PLMSW Organization: Bryan Health Date: 09/12/2024 Comment: Often patients have comorbidities. While doing sleep studies, I often saw providers ordering sleep studies in hopes that patients would have sleep apnea as well as their COPD. They were desperately looking to provide support to ventilation at home. They were hoping NCPAP could provide at least "something". The criteria for home ventilation have made it too hard to qualify patients until they are end of life. Earlier NIPPV treatment will reduce hospitalizations, and visits to the ER. Easy access to NIPPV will also have the potential to reduce procedures like tracheostomies to provide invasive ventilation. This will also cut down on readmission with infections from tracheostomies. Lower PCO2 and higher PO2 will provide patients improved cognition and mobility which can also lead to less falls, less broken bones, and decreased hospital admissions. Increasing this area of treatment in the home surely will improve quality of life and reduce hospitalizations. Less Often patients have comorbidities. While doing sleep studies, I often saw providers ordering sleep studies in hopes that patients would have sleep apnea as well as their COPD. They were desperately looking to provide support to ventilation at home. They were hoping NCPAP could provide at least "something". The criteria for home ventilation have made it too hard to qualify patients until they are end of life. Earlier NIPPV treatment will reduce hospitalizations, and visits to the ER. Easy More
Blair, Raymond	Title: Director of Government Programs/MSSP Med Dir. Organization: Privia North Texas Date: 09/11/2024 Comment: Public Comment on CMS Reconsideration of NCD 280.1: Home Noninvasive Positive Pressure Ventilation (NIPPV) for Chronic Respiratory Failure Due to COPD I am writing in response to the CMS request for public comments regarding the reconsideration of National Coverage Determination (NCD) 280.1, specifically focusing on the use of noninvasive positive pressure ventilation (NIPPV) in the home for patients with chronic respiratory failure (CRF) consequent to chronic obstructive pulmonary disease (COPD). Clinical Efficacy and Benefits of Home NIPPV There is substantial evidence supporting the clinical efficacy of long-term home NIPPV in patients with chronic respiratory failure due to COPD. Multiple studies demonstrate that home use of bilevel positive airway pressure (BPAP) and home mechanical ventilators (HMVs) significantly reduces mortality rates, decreases hospital admissions, and delays the need for invasive mechanical ventilation. A meta-analysis including 51,085 patients showed that BPAP reduces mortality (odds ratio 0.66), lowers the frequency of hospital admissions (odds ratio 0.22), and decreases the need for intubation (odds ratio 0.34)?(JAMANetwork). Furthermore, a study examining long-term nocturnal noninvasive ventilation found improvements in health-related quality of life (HRQoL) and reductions in exacerbation rates when added to rehabilitation programs?(BioMed Central). Improved Outcomes Through Hypercapnia Management Managing hypercapnia is a key intervention for improving outcomes in COPD patients with chronic respiratory failure. The European Respiratory Society (ERS) provides evidence-based guidelines recommending long-term home noninvasive ventilation (LTH-NIV) to improve outcomes by reducing carbon dioxide levels in these patients. Such management is associated with fewer COPD exacerbations, lower mortality rates, and improved HRQoL?(ERS Journals). These guidelines underscore the importance of using NIPPV in patients with hypercapnic COPD as part of a comprehensive treatment strategy. Addressing Health Disparities and Health Equity It is essential to consider health disparities when evaluating access to home NIPPV for patients with COPD. Patients from underserved communities often face challenges in accessing specialized respiratory care, which can exacerbate outcomes in chronic respiratory failure. The availability of home NIPPV can play a crucial role in reducing emergency room visits and hospital readmissions in these populations, improving overall care access and reducing disparities in health outcomes. Conclusion Based on the clinical evidence, it is clear that NIPPV, particularly BPAP and HMV, is a critical intervention for managing chronic respiratory failure in COPD patients. Home NIPPV has been shown to improve survival rates, reduce hospitalizations, and enhance the quality of life for these patients. CMS should consider expanding coverage to ensure equitable access to these therapies, particularly for vulnerable populations at greater risk of adverse outcomes. Please find detailed scientific references below: JAMA Network Study on NIPPV and Outcomes in COPD https://jamanetwork.com/journals/jama/fullarticle/2760390 Respiratory Research Study on NIPPV in Home Settings https://respiratory-research.biomedcentral.com/articles/10.1186/1465-9921-12-112 European Respiratory Society Guidelines on Long-term NIPPV https://erj.ersjournals.com/content/54/3/1901003 Thank you for considering this evidence in the development of the new NCD section. Less Public Comment on CMS Reconsideration of NCD 280.1: Home Noninvasive Positive Pressure Ventilation (NIPPV) for Chronic Respiratory Failure Due to COPD I am writing in response to the CMS request for public comments regarding the reconsideration of National Coverage Determination (NCD) 280.1, specifically focusing on the use of noninvasive positive pressure ventilation (NIPPV) in the home for patients with chronic respiratory failure (CRF) consequent to chronic obstructive pulmonary disease More

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