Medicare CPAP Resupply Schedule by Supply Code

Matteo

Updated October 2026. Written by Matteo Grassi, clinical psychologist and cofounder of HANA Health.

The Medicare CPAP resupply schedule is the list of usual maximum quantities that LCD L33718 allows for masks, cushions, tubing, filters and other accessories. Under the revision effective January 2024, a full face cushion is allowed once a month, a complete mask or tubing once every three months, and disposable filters twice a month. A supplier can't dispense more than three months at a time.

Most resupply problems I see aren't coding problems. They're timing and documentation problems, and the timing rules are stricter than many DME teams remember.

Key facts

The current revision of LCD L33718 applies to services on or after January 1, 2024, and sets usual maximums for 15 accessory codes.
A full face cushion (A7031) is allowed 1 per month, and a complete full face mask (A7030) is allowed 1 per 3 months, per the 2024 LCD table.
Disposable filters (A7038) are allowed 2 per month. Standard tubing (A7037) and heated tubing (A4604) are allowed 1 per 3 months each.
Under the same LCD, a supplier may contact the patient about a refill no sooner than 30 calendar days before the expected end of the current supply, and may deliver no sooner than 10 calendar days before it.
Suppliers must not dispense more than a 3 month quantity at a time, and must not ship refills without a documented affirmative response, per LCD L33718.
CMS reported a 12.5% improper payment rate for CPAP in its 2024 reporting period, a projected $146.1 million, and 71.2% of those improper payments came from insufficient documentation (CMS MLN).
In a 2024 study of 213,341 commercially insured patients, 48% met the CMS adherence standard in all four quarters of the first year (Alpert et al., Chest).

How often does Medicare cover CPAP masks, cushions, tubing and filters?

Medicare covers CPAP accessories at the frequencies set in the policy's accessory table, as long as the patient still meets the coverage criteria for the PAP device. Those are usual maximums, not entitlements. Quantities above them are denied as not reasonable and necessary.

Accessories are only payable when the device itself is covered. If the adherence and reevaluation requirements in the first three months weren't met, the accessories are denied too. I covered those requirements in Medicare CPAP compliance requirements and the CPAP face to face reevaluation post.

The LCD also expects suppliers to stay attuned to atypical utilization. If a patient needs more than the usual maximum, the supplier has to verify with the treating practitioner that the change is warranted.

Code by code limits

A7030: full face mask, complete. 1 per 3 months.
A7031: replacement cushion for a full face mask. 1 per month.
A7027: combination oral and nasal mask. 1 per 3 months.
A7028: oral cushion for a combination mask. 2 per month.
A7029: nasal pillows for a combination mask, per pair. 2 per month.
A7034: nasal interface, mask or cannula type. 1 per 3 months.
A7032: replacement cushion for a nasal mask. 2 per month.
A7033: replacement nasal pillows, per pair. 2 per month.
A7035: headgear. 1 per 6 months.
A7036: chinstrap. 1 per 6 months.
A7037: tubing. 1 per 3 months.
A4604: heated tubing. 1 per 3 months.
A7038: disposable filter. 2 per month.
A7039: nondisposable filter. 1 per 6 months.
A7046: replacement water chamber for a humidifier. 1 per 6 months.

The annual math

Here's how those limits convert to a yearly ceiling for a single code:

1 per month is 12 a year, so A7031 tops out at 12 cushions.
1 per 3 months is 4 a year, so A7030, A7037 and A4604 top out at 4 each.
1 per 6 months is 2 a year, so A7035, A7036, A7039 and A7046 top out at 2 each.
2 per month is 24 a year, so A7038 tops out at 24 disposable filters.

The LCD sets the ceiling per code. It doesn't say a given patient will need every item at the maximum rate, and it doesn't say how combinations of a complete mask and separate cushions should be handled in the same period. Ask your DME MAC about that case.

What is the refill contact rule, and can a supplier auto ship?

No. Medicare doesn't allow automatic shipment of refills, even if the patient authorized it. For recurring supplies, the supplier has to contact the patient and document an affirmative response before dispensing each refill. Items delivered without a valid, documented refill request are denied as not reasonable and necessary.

The rule has two windows, and both count from the expected end of the current supply:

Contact window: no sooner than 30 calendar days before the expected end of the supply.
Delivery window: no sooner than 10 calendar days before the expected end of the supply.

Here's a worked example. A patient's cushion supply is expected to end on March 31.

The supplier can contact the patient starting March 1, which is 30 days before.
The supplier documents the patient's yes, plus any change to the order.
The supplier can ship starting March 21, which is 10 days before.
The supplier never ships more than a three month quantity in one delivery.

The LCD revision that set the 30 day contact window took effect on January 1, 2024. It aligned the policy with CMS Final Rule CMS-1780-F. Billing has to follow prospective use, not retrospective use.

What documentation does a CPAP resupply claim need?

A resupply claim needs the standard order, medical record support for continued need, correct coding, proof of delivery and refill documentation. The LCD lists all five as general documentation requirements for DMEPOS items. Documentation is where CPAP claims usually fail. CMS reported that insufficient documentation drove 71.2% of improper payments for PAP devices in 2024.

A few details from the policy article A52467 are easy to miss:

The order must list the type of supplies and the approximate quantity to be used per unit of time. A new order is required if the quantity or type of supply used increases.
The supplier must put the PAP diagnosis code on each supply claim.
Mask liners are a comfort and convenience item. They're noncovered and should be coded A9270, not billed as a replacement interface.
Claim lines need a KX, GA or GZ modifier. Without one, the line is rejected as missing information.

Keep the refill contact log with the claim file. If a reviewer asks for it, a dated record of the patient's yes is the strongest piece of evidence you have.

Do accessories stay covered after the 13 month rental ends?

Yes, in many cases. After Medicare has paid for 13 months of continuous use of the base device, the patient owns it, and medical necessity for the base device is assumed to have been established. Accessory claims for that patient then need less proof. Under policy article A52467, the documentation has to show two things.

The base device still meets the patient's medical need, and that comes from the treating practitioner's records.
Replacing the specific accessories is still necessary for the device to work, and that comes from the supplier's records.

The same article says this guidance doesn't apply when Medicare didn't pay for the base item originally. In that case, all coverage, coding and documentation requirements for the date of service apply, including the adherence criteria.

One more rule matters here. If a patient stops using the device, the supplier is expected to find out and stop billing for the equipment and related supplies. That makes the refill call more than a formality. It's also your check on whether the patient is still using therapy.

Why does resupply depend on adherence data, not just claims?

Resupply claims are a weak stand in for whether a patient is actually using therapy. The Alpert study linked claims to device data for 213,341 commercially insured adults. By device data, 48% were adherent in all four quarters of year one. Claims based definitions labeled anywhere from 10% to 84% of patients as adherent, depending on the algorithm.

Patients who used the device consistently were often marked nonadherent by claims. Patients who used it inconsistently were often marked adherent. The study covers commercially insured patients and a single device platform, so it doesn't prove the same gap exists in Medicare fee for service. It does show why a shipped box isn't proof of therapy.

For a DME, that means the refill call is your best chance to learn what the claim can't tell you. Ask whether the mask still seals, whether the cushion is worn, and whether the patient is using the device most nights. A patient who has quietly stopped is a coverage risk and a clinical one.

What this means for your DME

Treat the resupply schedule as a calendar, not a catalog. For each patient, track the expected end date of every item, open the contact window 30 days before it, and deliver no earlier than 10 days before. Document the yes every time.

Then use the call. A refill conversation is a few minutes of attention on a patient whose adherence may be slipping. HANA Sleep is built around that follow up for CPAP adherence. Whatever tool you use, make sure the contact is real, documented and tied to the patient's actual use.

Frequently asked questions

Can a patient get a replacement mask sooner than the schedule allows?

Quantities above the usual maximum are denied as not reasonable and necessary under the LCD. Suppliers have to verify atypical utilization with the treating practitioner. Whether a specific extra claim is payable is a question for your DME MAC.

Does Medicare pay for mask liners?

No. Policy article A52467 treats liners as comfort and convenience items with no additional payment. They're coded A9270 as a noncovered item.

Can I mail a standing resupply kit every quarter?

Not on a fixed schedule. You need contact with the patient and a documented affirmative response before each refill, and the delivery has to fall inside the 10 day window.

How much can I ship in one delivery?

No more than a three month quantity at a time, regardless of utilization.

Do commercial and Medicaid plans use the same schedule?

Not necessarily. Commercial and Medicaid plans set their own limits and refill rules, so check each payer's current policy before you assume the Medicare table applies.

Sources

Centers for Medicare and Medicaid Services, Local Coverage Determination L33718: Positive Airway Pressure (PAP) Devices for the Treatment of Obstructive Sleep Apnea, revision effective January 2024.
Centers for Medicare and Medicaid Services, Policy Article A52467: Positive Airway Pressure (PAP) Devices for the Treatment of Obstructive Sleep Apnea, revision effective August 2021.
Centers for Medicare and Medicaid Services, Medicare Learning Network: Continuous Positive Airway Pressure Devices and Accessories, 2024 reporting period.
Alpert N, Cole KV, Dexter RB, Sterling KL, Wickwire EM, Performance of Claims Based Algorithms for Adherence to Positive Airway Pressure Therapy in Commercially Insured Patients With OSA, Chest, 2024.

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill. If you want to talk through how to structure CPAP resupply outreach, book a call with Matteo.