Sleep medicine is one of Medicare’s more complex provider categories because it spans multiple enrollment types: the sleep study facility, the interpreting physician, the sleep technologist, and — if you’re supplying CPAP equipment — a DMEPOS supplier. Getting all of these enrolled correctly and in the right sequence is what separates practices that bill successfully from those that get stuck in denials.
The four components
1. The interpreting physician Physicians who interpret polysomnograms must be enrolled via CMS-855I. Board certification in sleep medicine (ABIM, ABS, ABPed, or ABSM subspecialty) is strongly recommended and increasingly required by MACs for coverage of certain study types.
2. The sleep laboratory (facility) Freestanding sleep laboratories that bill independently must be accredited by the AASM, ACHC, or The Joint Commission. Without accreditation, many MACs will not cover diagnostic sleep studies billed by the facility. The facility enrolls via CMS-855B (if it’s an independent entity) or may bill under a hospital or clinic’s enrollment.
3. Sleep technologists Registered Polysomnographic Technologists (RPSGTs) and other sleep technologists typically bill incident-to the supervising physician — they do not independently enroll in Medicare. If you’re billing for technologist services independently, check your MAC’s guidance; this is a frequently-audited area.
4. CPAP and DMEPOS If your practice supplies CPAP equipment directly to patients, you must enroll as a DMEPOS supplier via CMS-855S. This is a separate enrollment from your clinical enrollment and carries its own accreditation requirement (ACHC or The Joint Commission for DMEPOS). You must also have a surety bond.
Coverage requirements for polysomnography
Medicare covers attended, in-lab polysomnography (CPT 95810, 95811) and home sleep apnea tests (HSATs, CPT 95800, 95801, 95806) under specific medical necessity criteria:
- Documented symptoms of obstructive sleep apnea (excessive daytime sleepiness, loud snoring, observed apneas)
- Prior sleep study result for CPAP titration studies (95811)
- For HSATs: patient must have high pretest probability of moderate-to-severe OSA with no comorbidities that would require full PSG
⚠️ Risk flag: Home sleep testing (HSAT) coverage is MAC-specific. Some MACs have Local Coverage Determinations (LCDs) that restrict HSAT coverage; others are more permissive. Check your MAC’s LCD before billing HSATs extensively.
CPAP resupply billing
CPAP resupply items (masks, tubing, filters) are DMEPOS items billed with HCPCS codes. They follow the competitive bidding program in most areas. If your practice is in a CBA, you must be a contract supplier to bill these items to Medicare — non-contract suppliers cannot bill Medicare Part B for competitively bid DMEPOS items in a CBA.
Key applications
- CMS-855I — interpreting physician enrollment
- CMS-855B — sleep lab as independent entity
- CMS-855S — DMEPOS supplier enrollment (if supplying CPAP)
- CMS-855R — reassignment if physicians bill under the lab’s NPI
Ask Mae if you have questions about your specific sleep medicine billing situation — lab accreditation, CPAP supplier enrollment, or HSAT coverage in your region.