CHEST Submits Public Comment to CMS on NIPPV Proposed Decision Memo

April 10, 2025

The American College of Chest Physicians (CHEST) recently submitted a public comment to the Centers for Medicare and Medicaid Services (CMS) in response to its proposed decision memo for “Noninvasive Positive Pressure Ventilation in the Home for the Treatment of Chronic Respiratory Failure consequent to COPD (tracking number: CAG-00465N).”

This is a pertinent issue for CHEST membership—comprising more than 18,000 pulmonary, critical care, and sleep medicine clinicians—as it ensures that the therapies and interventions that clinicians prescribe will be appropriately accessible to their patients without challenge.

CHEST replied with several suggestions—including initial coverage criteria and continuing usage criteria—that are critical to ensuring patient access and optimizing outcomes.

The recommendations include:

• We suggest consistent use in the continuing usage criteria for a RAD or HMV be defined as use of the device for an average of at least 4 hours per day on 70% of days within a 30-day period. Requiring 5 hours of usage every night for patients will be overly burdensome and is impractical. 
• While we agree with the recommendation for re-evaluation for RAD by day 180, we feel that requiring subsequent evaluation every 6 months thereafter is overly burdensome to patients and would worsen patient access to evidence based care.
• We suggest a change in how stable COPD is defined. Requiring a 4-week period without change in pharmacologic management will be burdensome to the patient and could delay evidence-based care. 

CMS is expected to complete its national coverage analysis in early June.

Read the full letter to CMS.