💤 PAP / BiPAP Documentation Checklist

Usage

Use this checklist for all Initial Coverage (Months 1-3), Continued Coverage (Month 4+), and Supply Refills.

1. Initial Coverage (Months 1-3)

Required for first billing of E0601 (CPAP) or E0470 (BiPAP).

Standard Written Order (SWO)

  • Basic Elements: Beneficiary Name/MBI, Order Date, Treating Practitioner Name/NPI, and Signature?
  • Description: Brand Name/Model or HCPCS code.
  • Accessories: Are all separately billable items (mask, tubing, filters) listed individually?

Face-to-Face Clinical Eval

Must be completed prior to the sleep test.

  • Symptoms: Documented sleep disordered breathing (snoring, daytime sleepiness, apneas, gasping)?
  • Physical Exam: Focused cardiopulmonary/upper airway eval, Neck Circumference, and BMI recorded?
  • Epworth Scale: Validated sleep hygiene inventory (e.g., Epworth) included?

Sleep Study (Qualifying Criteria)

Must be FDA-approved and ordered by the treating practitioner.

  • AHI/RDI ≥ 15: Covered automatically.
  • AHI/RDI 5–14: Covered ONLY with documentation of:
    • Excessive daytime sleepiness/insomnia/mood disorders; OR
    • Hypertension, ischemic heart disease, or history of stroke.

Additional BiPAP (E0470) Criteria

  • CPAP Failed: Documented trial of CPAP (E0601) proved ineffective?
    • Was mask fit/comfort addressed?
    • Were pressure adjustments tried?
  • Switch Rule: If switching < 30 days into trial, no new face-to-face needed. If > 3 months, new face-to-face required (but no new sleep test).

2. Continued Coverage (Month 4+)

Required to continue billing beyond the 3rd month.

  • Clinical Re-evaluation: Occurred between Day 31 and Day 91 of therapy?
  • Benefit Documented: Note states patient is benefiting (symptoms improved)?
  • Adherence (Usage): Objective data download verifies use ≥ 4 hours/night on 70% of nights for any 30-day consecutive period?
  • Dr Review: Treating practitioner reviewed the adherence report?

3. Refill Requests (Supplies)

Rules effective Jan 1, 2024.

  • Request Date: Contact occurred no sooner 30 days before current supply ends?
  • Affirmative Need: Patient specifically confirmed they need the refill (no auto-ship)?
  • Functional Condition: For non-consumables, is the dysfunction/damage documented?

4. Delivery & Modifiers

  • Delivery Ticket: Includes Brand, Model, Serial #, and Delivery Date?
  • Signatures: Signed by patient (or rep) with relationship noted?
  • KX Modifier:
    • Months 1-3: Applied ONLY if all Initial Coverage criteria met.
    • Month 4+: Applied ONLY if both Initial AND Continued Coverage (Adherence) criteria met.
  • GA Modifier: Applied if expecting denial (ABN on file)?

5. Replacement & 5-Year RUL

For replacement after the 5-year Reasonable Useful Lifetime (RUL) or due to loss/damage.

5-Year RUL Renewal

  • New SWO: Required for the replacement device.
  • Face-to-Face Eval: Treating practitioner documents that the beneficiary continues to use and benefit from the device.
    • Note: A new sleep test is NOT required if the original qualifying test is on file.

Replacement (Loss, Theft, or Damage)

If replacing < 5 years due to specific incident.

  • Incident Documentation: Police report, insurance report, or fire report verifying the specific incident.
  • Narrative: Statement detailing the reason for replacement (lost/stolen/destroyed).

6. Beneficiaries Entering Medicare

For patients who had a PAP before joining Medicare and now want coverage.

  • Prior Sleep Test: Documentation of a sleep test (completed prior to Medicare enrollment) that meets current Medicare AHI/RDI coverage criteria.
  • Clinical Eval (Post-Enrollment): An in-person eval after their Medicare start date where the practitioner documents:
    • The beneficiary has a diagnosis of OSA.
    • The beneficiary continues to use the PAP device.
  • New SWO: A current Standard Written Order for the device.
  • A new compliance period is not required

Download

Download the PAP Device Checklist (PDF)