Medicare qualifications for a Sleep Technician

Sleep studies performed on patients with medicare at an IDTF must be done by appropriately certified technicians. Below is the regulation (copied from an old reader comment):

CMS document 410.33 (2)(c) states "Nonphysician personnel. Any non-physician personnel used by the IDTF to perform tests must demonstrate the basic qualifications to perform the tests in question and have training and proficiency as evidenced by licensure or certification by the appropiate State health or education department. In the absence of a State licensing board, the technician must be certified by an appropiate national credentialing body. The IDTF must maintain documentation available for review that these requirements are met."

In most states there is no state licensure for sleep technicians.

It is fairly well accepted that the RPSGT and RRT credentials meet CMS requirements. It is unclear if RN (or LPN) is acceptable. The CPSGT credential is probably not sufficient, but I have not seen this officially.

If any readers have any clarification on this regulation, I would appreciate a comment.

Please note, this regulation applies only to IDTF's, not to hospital-associated sleep labs or to sleep labs organized as an extentsion to a physician practice.

Billing for Sleep Studies

I recently received an email asking about billing globally for sleep studies vs billing the professional and technical components separately. I came across this reference today:

http://www.arkmedicare.com/provider/viewarticle.aspx?articleid=8365

CPT 95805: Multiple sleep latency or maintenance of wakefulness testing, recording, analysis and interpretation of physiological measurements of sleep during multiple trials to assess sleepiness.
CPT 95810: Polysomnography; sleep staging with 4 or more additional parameters of sleep, attended by a technologist.
CPT 95811: Polysomnography; sleep staging with 4 or more additional parameters of sleep, with initiation of continuous positive airway pressure therapy or bi-level ventilation, attended by a technologist.

If a provider bills for the codes listed above without modifiers, the technical AND professional components are included in payment. If the professional component was not provided by a facility, the facility should bill the code using the TC modifier and the interpreting physician may bill with the -26 modifier. If the facility employs a provider who performs the professional component, then the facility may bill for the global code (without a modifier or the code with the -26 AND -TC modifiers).

prn MSLT's

A doctor asked on the AASM message board about prn (as needed) MSLT's. In his sleep medicine group, doctors sometimes order a nocturnal polysomnogram to evaluate for OSA, with instructions to the technicians to perform an MSLT if OSA is not found.

Should the practice of "prn" MSLT be abandoned? Is it a bad idea?

Here is my answer to the the doctor's question?

yes and yes.

If you think someone has narcolepsy/idiopathic hypersomnia it is reasonable to order a psg/MSLT with instructions that the MSLT be canceled if OSA is present (with the sleep physician being avaliable in the am to review the psg in borderline cases).
I think it is unreasonable and puts too much responsibility on the techs to have them decide whether an MSLT is neeed on large numbers of patients being evaluated for OSA.