Skip to main content
U.S. flag

An official website of the United States government

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

Beta This is a new resource - your feedback will help us improve it.

Supplier Compliance with Medicare Requirements for Replacement of Positive Airway Pressure Device Supplies

Announced on  | Last Modified on  | Project Number: A-05-21-00036
Status
Completed
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

Beneficiaries receiving continuous positive airway pressure or respiratory assist device (collectively known as positive airway pressure (PAP) devices) therapy require replacement of supplies (e.g., mask, tubing, headgear, and filters) when they wear out or are exhausted. Medicare payments for these replacement supplies in 2017 and 2018 were approximately $945.8 million. Prior OIG work found that most Medicare claims that suppliers submitted for replacement PAP device supplies did not comply with Medicare requirements. For supplies and accessories used periodically, orders must specify the type of supplies needed, the frequency of use, if applicable, and the quantity to be dispensed, and suppliers must not automatically ship refills on a predetermined basis (Centers for Medicare & Medicaid Services Medicare Program Integrity Manual, Pub. 100-08, Ch. 5, §§ 5.2.3 and 5.2.8). We will review claims for frequently replaced PAP device supplies at selected suppliers to determine whether documentation requirements for medical necessity, frequency of replacement and other Medicare requirements are met.

TIMELINE

  • September 1, 2021
    Announced
  • April 23, 2026
    Complete

    Supplier Compliance with Medicare Requirements for Replacement of Positive Airway Pressure Device Supplies complete. This audit resulted in 2 recommendations.

REPORT PUBLISHED

Medicare Payments for Positive Airway Pressure Devices Used for the Treatment of Obstructive Sleep Apnea Generally Complied With Medicare Requirements (A-05-21-00036)

CMS generally ensured that payments made to suppliers for PAP devices complied with Medicare billing requirements. Medicare payments to suppliers complied with Medicare billing requirements for 97 sampled PAP device claims. However, for the remaining 13 sampled PAP device claims, Medicare payments to suppliers did not comply with Medicare billing requirements. Specifically, Medicare made payments for PAP device claims that did not have the required documentation to support the services billed. In addition, some suppliers did not respond to OIG’s request for documentation to support the PAP device claims that were billed to Medicare. As a result:

  • Medicare paid for PAP device claims that did not have all the necessary documentation
  • We estimated that Medicare paid approximately $15.2 million for improper PAP device claims during our audit period that did not meet Medicare billing requirements

26-A-05-063.01 to CMS - Open Unimplemented
Update expected on 10/22/2026
We recommend that CMS establish and implement internal controls to prevent improper payments for replacement PAP devices, which amounted to an estimated $15.2 million for our audit period.

26-A-05-063.02 to CMS - Open Unimplemented
Update expected on 10/22/2026
We recommend that CMS provide outreach and education to suppliers on coverage requirements for PAP devices used in treating OSA to prevent improper payments.

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Financial Stewardship
Target Groups
-
Financial Groups
Medicare B