AASM Seeks Fair Pay for New Sleep Test Codes

The American Academy of Sleep Medicine plans to submit comments to the Centers for Medicare & Medicaid Services regarding the valuation of new unattended sleep testing CPT codes 95X18-95X23. These codes will replace the current codes 95800, 95801, and 95806 starting January 1, 2027, according to the source.

In a call to action, the AASM is encouraging sleep physicians, sleep centers, and other stakeholders to also submit comments to CMS. The goal is to support appropriate valuation to ensure continued patient access to high-quality unattended sleep testing and fair reimbursement for services.

The new codes were developed through the American Medical Association CPT and Relative Value Scale Update Committee processes. They were created in collaboration with the American Academy of Neurology, American College of Chest Physicians, and the American Thoracic Society. The AASM states the codes reflect technological advances, better capture complexity levels, and support a broader range of sleep disorders.

Key Issues in the Proposed Rule

The AASM has identified several key issues in the CMS proposed rule. It will clarify the clinical staff time and activities required for unattended testing. These activities include patient education, equipment training, sensor placement instruction, and quality assurance review. The AASM will urge CMS to finalize the RUC-recommended clinical staff times without reduction.

The academy will also support the RUC recommendation that equipment be assigned 960 minutes of equipment time. It notes the device remains dedicated to a single patient throughout instruction, testing, and return. CMS should retain this proposed time because it reflects typical clinical workflows.

Furthermore, CMS has requested additional invoices and market data to establish pricing for equipment and supplies. The AASM will encourage CMS to consider all supplemental invoices before finalizing direct practice expense pricing. Relying on limited data could undervalue necessary equipment.

Dispute Over Physician Work Value

A specific point of contention involves the work RVU for CPT code 95X23. CMS accepted RUC-recommended work RVUs for codes 95X21 and 95X22. However, the agency proposed reducing the work RVU for code 95X23 from 1.60 to 1.42.

The AASM strongly disagrees with this reduction. It argues the change would undervalue the physician work required to interpret the most complex unattended sleep studies. These studies require review of multiple physiologic signals, evaluation of data quality and artifacts, identification of respiratory events, and synthesis of findings into a diagnostic report. The AASM will urge CMS to finalize the RUC-recommended work RVU of 1.60.

The AASM will also request that CMS update the utilization data analytic crosswalk in the proposed rule. As currently proposed, the crosswalk incorrectly assigns a disproportionate share of independent diagnostic testing facility utilization to moderate-complexity codes rather than low-complexity codes.

The Importance of Stakeholder Comments

The AASM states that CMS gives significant weight to comments submitted by physicians and provider organizations. It encourages members and accredited sleep centers to submit comments supporting fair valuation. Stakeholder comments that reinforce the AASM’s recommendations can help CMS better understand the clinical work, resources, and operational requirements for providing these services safely.

Members may download a template letter to assist in preparing a response. The AASM encourages personalizing comments by adding details about test utilization in individual practices or by providing device invoices. The public comment period closes before CMS publishes a final rule in late October or November 2026.

Next Steps and Resources

Once the comment period closes, CMS will review all submitted feedback. The final rule will be published in late October or November 2026, with changes effective January 1, 2027.

The AASM will release a suite of educational resources in the coming months to support code implementation. Education will include sessions at upcoming courses, new coding FAQs, webinars, a Talking Sleep podcast episode, and a quick reference guide for coders. A special updated sleep medicine coding module in Sleep-CODE and template letters for clinicians to send to payers are also planned.

Questions about the AASM comments or the submission process can be directed to coding@aasm.org.