A Guide to the New NCD for NIPPV

Published in Member Communities on August 06, 2025

By Ronda Buhrmester, Sr. Director of Payer Relations and Reimbursement, VGM & Associates

Medicare’s New NCD for CRF consequent to COPD 

The Centers for Medicare & Medicaid Services (CMS) has finalized a National Coverage Determination (NCD) that significantly expands access to non-invasive positive pressure ventilation (NIPPV) for patients with chronic respiratory failure (CRF) secondary to chronic obstructive pulmonary disease (COPD). Effective June 9, 2025, this decision introduces new coverage criteria for both respiratory assist devices (RADs) and home mechanical ventilators (HMVs) specific to the diagnosis of CRF consequent to COPD. 

Remains the Same 

The payment categories remain unchanged. This means the RAD device remains as a capped rental for 13 months of payment, where supplies are separately billable and payable. The NIV remains in the frequent and substantial servicing category, meaning it rents until the device is no longer needed, and supplies are included with the monthly allowable. 

Wins and Challenges 

There are wins with the new NCD, which include clearer clinical criteria for NIV and no oximetry or sleep study requirements for RAD devices. 

With wins come challenges. This includes increased documentation, no additional reimbursement, and the need for education for the suppliers’ referrals. In addition, there is a greater emphasis on patient outcomes and monitoring adherence to compliance requirements. 

Points of Attention 

The DME MACs are diligently developing language for an LCD that will be released in time that will include additional clarity to areas left up to their discretion. 

In the meantime, the biggest area of concern that suppliers need to discuss with their team and industry experts is the continued compliance requirements for each paid rental month. The NCD states that the patient must be using the device at least four hours per 24-hour period on 70% of days in each paid rental month. The discussion needs to be around how a supplier can manage this internally with staff and effectively to meet the policy requirements. If this is not sustainable, then consider outsourcing the monitoring to a reputable company. 

In Summary 

This NCD marks a pivotal shift in Medicare support for COPD-related CRF. The shift is not just for Medicare FFS. Suppliers need to monitor all other payers’ updates that may incorporate this NCD into their respective policies. This has already started with some payers. Suppliers need to prepare through education, training, and workflow adjustments to align with the new standards.  

Ronda Buhrmester 
Ronda.Buhrmester@vgm.com