D97-06 Reevaluating the Centers for Medicare and Medicaid Services 90-Day Cpap Adherence Requirement: Persistent Use Among Early Nonadherent Patients

Rationale In 2009, the Centers for Medicare & Medicaid Services (CMS) required patients with obstructive sleep apnea (OSA) to use continuous positive airway pressure (CPAP) ≥4 hours on 70% of nights within the first 90 days to maintain coverage. This policy assumed that poor early use predicts long-term abandonment. This determination was not evidence-based, and subsequent studies support symptomatic benefit from 2 to 3 hours of nightly use. We examined long-term use and rates of treatment abandonment within an integrated healthcare system which provides coverage irrespective of early usage levels. Methods We analyzed all adult OSA patients (≥18 years) dispensed CPAP between 2020-2023 within Kaiser Permanente Southern California. Patients were included if they had at least one recorded episode of device usage (confirming active wireless data transmission) during the one-year period after CPAP dispensation (Auto-set Airsense 10/11, Resmed Corp). Patients were stratified by 90-day CMS adherence status. CPAP use during “Month 12” (days 330-360 post-initiation) was assessed, including the proportion with any use, mean nightly minutes, and the percentage of nights ≥4 hours. We also calculated proportions averaging ≥2 hours and ≥4 hours per night. Results Among 132,492 patients (mean age 55.0±14.6 y; 65.5% male; mean AHI4% 32.5±25.0), 49.0% met 90-day CMS adherence, increasing to 53.5% in those ≥65 years of age. Failure to meet CMS adherence was associated with younger age, female sex, non-White race/ethnicity, lower socioeconomic status, and less OSA severity. At Month 12 (Table), 36% of patients not meeting CMS adherence still used CPAP. In this group, mean use was 197±160 min/night, with 42.9±36.0% of nights ≥4 hours. Overall, of all CMS non-adherent patients, 20.9% used CPAP ≥2 h/night and 13.6% ≥4 h/night during Month 12; among those ≥65 years of age, Month 12 usage was even greater at 23.3% ≥2 h/night and 16.5% ≥4 h/night. Conclusions Over one-third of patients not meeting the CMS 90-day adherence requirement continued CPAP use at one year with average usage at levels associated with symptomatic benefit. These results challenge the assumption that early non-adherence predicts treatment abandonment, and they support redefining CPAP success based on patient-centered outcomes rather than fixed usage thresholds. This abstract is funded by: American Academy of Sleep Medicine Foundation Strategic Research Award 205-SR-19