AASM Comments on Proposed HOPPS Rule for Unattended Sleep Testing

The American Academy of Sleep Medicine (AASM) has submitted comments on the proposed rule for the Hospital Outpatient Prospective Payment System (HOPPS) in 2027.

The AASM is concerned about the proposed payment policies for new unattended sleep testing Current Procedural Terminology (CPT) code family. They believe that CMS's proposal to assign moderate-complexity and high-complexity unattended sleep testing services to the same Ambulatory Payment Classification (APC) does not accurately reflect the differences in technology, resources, and operational costs required to furnish these services.

The AASM urges CMS to establish separate APC assignments to better reflect hospital resource utilization, support payment accuracy, and help ensure Medicare beneficiaries maintain access to clinically appropriate diagnostic testing options.

The AASM also emphasizes the importance of aligning HOPPS payment policies with the resource distinctions CMS has proposed under the Medicare Physician Fee Schedule. They highlight the potential impact on patient access, particularly for Medicare beneficiaries with complex clinical needs and those who rely on local hospital outpatient departments for sleep diagnostic services.

Comments on the Proposed Rule

The AASM is encouraging members to submit comments in response to the proposed rule. Comments from clinicians, sleep centers, researchers, and other stakeholders help demonstrate the real-world impact of Medicare payment policies on patient access and sleep care delivery.

Submission Deadline

Comments must be submitted by August 31, 2026. Members may submit questions about the rule or the AASM response to coding@aasm.org.

The AASM's comments aim to ensure that Medicare payment policies support patient access to clinically appropriate diagnostic testing options.