Medicare compliance update

20 November 2024 

The ASA has been communicating with members recently about the updated explanatory note for sleep study Medicare item numbers that came into effect on 1 July this year.

As mentioned in the recent member alert, ASA plans to write and publish a brief erratum to its recently-published Guidelines for sleep studies in adults to clarify any issues that have been identified. A writing group is also being formed to review and update the Australasian Commentary on the AASM Manual for the Scoring of Sleep and Associated Events (see below for the call for expressions of interest).

The President, Clinical Chair and CEO met with officers of the Department of Health and Aged Care (DOHAC) last week to discuss feedback on the new explanatory note, and how a couple of points of confusion might be addressed. Topics covered are listed below. 

• DOHAC noted the plans to update the ASA’s professional guideline documents mentioned in the explanatory note. 
  
• Compliance activity related to this will likely only happen when investigating suspected systemic concern or outlier billing practice. Interpretation of the professional guidelines will be guided by clinicians, and variations to what is literally written will be acceptable as long as there is documentation of a reasonable rationale.
  
• It was agreed that Medicare compliance staff will be approached to run a webinar early in 2025 to provide general and specific education to ASA members (see below for how to ask a question for the team to answer during the webinar).
  
• There will also be fact sheets available in due course as required. DOHAC staff reminded ASA members that all medical indemnity providers and the AMA have general education available on demand about billing obligations and how Medicare works. 
• The discussion made it clear that item 12250 refers to level 2 full polysomnography at home. Any change to this would require a separate MSAC application. 
  
• DOHAC staff also raised the issue that booking or set-up fees cannot be charged as part of any Medicare item that is bulk billed, such as home sleep studies.

Got questions?
If you’d like to send in a question for the Medicare compliance team to answer during the ASA webinar early next year, please send it to Marcia Balzer and she will pass it on.

Members will also be able to ask questions at the time of the webinar, but knowing the key concerns in advance will help ensure the right people are presenting and available for the webinar.

Call for expressions of interest
There is a joint ASA/ANZSSA working group being formed to review and update the Australasian Commentary on the AASM Manual for the Scoring of Sleep and Associated Events. 

There are vacancies for one more sleep scientist and two physicians to join the working group.

To express your interest in being involved, please send your CV with a short paragraph about why you’re keen to be involved to Cassie Real by Friday 13 December.