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May 10, 2017

SLEEP LAB CREDENTIALING:  Polysomnography and Other Sleep Studies (L36902)

CGS has received many inquiries regarding the credentialing of sleep labs under this LCD. The confusion lies in differentiating between accreditation and credentialing, as well as general versus sleep specific credentialing. The intent of the LCD and the coverage guidance is to ensure that Medicare beneficiaries are being diagnosed and treated by providers and in facilities that meet the specialty standards that ensure the highest accuracy and quality. Accreditation ensures safety and adherence to standards required for facility operations while credentialing addresses training and specialty board academic standards.

This article will clarify the credentialing of sleep labs in Jurisdiction 15.

Sleep disorder clinics are facilities in which certain conditions are diagnosed through the study of sleep. Such clinics are for diagnosis, therapy, and research. Sleep disorder clinics may provide some diagnostic or therapeutic services which are covered under Medicare. These clinics may be affiliated either with a hospital or a freestanding facility. Whether a clinic is hospital-affiliated or freestanding, coverage for diagnostic services under some circumstances is covered under provisions of the law different from those for coverage of therapeutic services. (CMS publication 100-02 Medicare Benefit Policy Manual, Chapter 15, Section 70)

The LCD states clearly the credentialing criteria:

  • The sleep facility credentials must be from the American Academy of Sleep Medicine (AASM), inpatient or outpatient;
    OR
  • The Joint Commission (formerly the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) sleep specific credentials for Ambulatory care sleep centers.
    OR
  • Accreditation Commission for Health Care (ACHC)

CGS understands that some sleep labs may not have the credentialing required by the LCD. To allow the labs to become compliant with minimal provider burden the following process will be implemented:

  1. All sleep labs must apply for credentialing by one of the organizations listed above as stated in the LCD within 90 days of the publication of this article.  The application and a letter from the credentialing organization that verifies that an application is in process must be available upon request by CGS.
  2. All sleep labs must have final credentialing by one of the organizations listed above as stated in the LCD in place within 12 months of the publication of this article.
  3. A sleep lab may request an extension if needed. The need for an extension should be very rare and will be granted for extenuating circumstances only.

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