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Pete Weber, BA, RRT, RPSGT

1. Understand screening vs. Study for sleep related issues

2. Learn possible issues with enticement for offering free sleep studies

3. Understand downside to free sleep screenings

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University of South Carolina

Feb 2012 Branden Gary, Jared Hanson, Michael Miller, Ganesh Rajagopalan, and Michael Shear

1300 Sleep Centers in US

Economic Outlook for next three years

Business expected to:

Expand slightly (46%)

Stay the same (30%)

Largest concerns (excluding “other”)

Healthcare consolidation (32%)

Reduced demand (22%)

University of South Carolina

Feb 2012 Branden Gary, Jared Hanson, Michael Miller, Ganesh Rajagopalan, and Michael Shear

1300 Sleep Centers in US

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Apr 2011 – Mar 2012

106 Sleep Center

35 States

Apr 2011 – Mar 2012

106 Sleep Center

35 States

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STOP QUESTIONNAIRE

Date of Surgery: _________________ Has CPAP use:___________________

Place patient sticker here:

FAX copy of this questionnaire to Sleep Lab at 7453.

Make additional copy of this questionnaire to send to pre-op with anesthesia report.

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Bellin Hospital Sleep Center in Green Bay, WI

1300 Sleep Centers in US

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SEPTEMBER 27‚ 2010

CMS Implements Self-Referral Disclosure Protocol Process to Self-

Disclose Stark Law Violations

Self-Referral specific to Physicians

The AASM has warned me that Free Sleep Screening

Could be interpreted as Enticement for Sleep Studies.

To date: Bellin has been able to provide services to our community

That benefit every person and this is not viewed as enticement

Enticement?

Actual wording by CMS is inducement:

Bellin has a Compliance Program that deals with the 7 standards:

1. Written Standards of Conduct

2. Designate a Compliance Officer

3. Effective Compliance Training

4. Internal Monitoring and Auditing

5. Disciplinary Mechanism

6. Effective Line of Communication – Compliance officer to Staff

7. Procedures for Responding and Correcting Offenses

Enticement?

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CMS requires organizations to have a compliance plan 42C.F.R

422.503 (b) (4) (vi) and 42C.F.R 423.504 (b) (4) (vi)

Enticement A.K.A Inducement

The Patient Protection and Affordable Care Act created an exception

to this standard by carving out of the definition of remuneration any

item or service “which promotes access to care and poses a low risk

of harm to patients and Federal health care programs (as defined in

section 1128B(f) [of the Social Security Act] and designated by the

Secretary under regulations).” Regulations to implement this new

exception have not been created. Jan 28, 2011

Enticement A.K.A Inducement

As of Feb 2012, the OIG of the CMS has not

Added any exceptions, as a general rule for all

Medicare patients.

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Enticement A.K.A Inducement

Medicaid Enrollees, WI, FY2006-2008

State of WI – Medicaid Plan

Defaults to National Level plan

No defiinition of inducement but reference to

CMS standards

March 2011 – Feb 2012

109 Sleep Center

34 States

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Requirements for Testing if you screen for OSA

There must be a face-to-face visit

with the physician prior to ordering the sleep test.

The sleep study results are: AHI or RDI is greater than or equal to 15 events per

hour, with a minimum of 30 events; or

AHI or RDI is 5-14 events per hour (minimum of 10 events) with documentation of excessive daytime sleepiness, impaired cognition, mood disorders, insomnia, hypertension, ischemic heart disease, or history of stroke.

Requirements for keeping therapy with a patient

To continue coverage for the positive airway pressure (PAP) device (CPAP or RAD) beyond an initial 3 month trial period, there must be:

A face-to-face visit with the physician during the second or third month of the trial that documents an improvement of the beneficiary's symptoms; and

A data report from the PAP device which documents use the PAP device for at least 4 hours per night on 70% of nights for a 30 consecutive day period during the trial.

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Bellin Hospital Sleep Center in Green Bay, WI

Bellin Sleep Study Volumes 2008 to 2012

40

50

60

70

80

90

100

110

120

130

1 4 7 10 13 16 19 22 25 28 31 34 37 40

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Bellin Sleep Center 2008 - Feb 2012

Studies vs. Screenings

0

20

40

60

80

100

120

140

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55

PSG

AL

Providing “Free” to our community has helped

us keep our volumes

Upside to “Free”…..

Cost per Apnea Link close to $75/Screening, Recoup costs

With maintenance of volume due to screening

60+% of positive apnea links have a sleep study

Customers appreciate the low cost and stay loyal

Customer base expanded

Since this is free, the customers insurance does not know

Specialties like Cardiology and Neurology engaged in sleep

Growth of screening has positioned us to easily do HST

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Conclusion

1. Free Sleep Screening is a great service

2. Enticement / Inducement is not an issue

3. Leads to team and customer by-in for HST

4. Sustains Volume in poor economy

5. Bellin Sleep Center must be sure to screen eligible

patients so we do not offer this value to Medicare Pts.

Thank You!

Transcranial Magnetic Stimulation