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[split] OSCAR & Compliance Reports
#1
[split] OSCAR & Compliance Reports
(03-08-2019, 12:32 PM)SuperSleeper Wrote:
(03-08-2019, 11:51 AM)KSMatthew Wrote: I'll probably load OSCAR and print reports from it and SH to compare side by side.  We use these compliance reports for annual FAA requirements.  FAA requires a 12 month report of compliance data and also requires 6 hrs/night vs 4 that a lot of insurance plans require.

I suspect that OSCAR will be like SleepyHead in that no "official" government agency will accept compliance reports from  anything except "officially sanctioned" proprietary reporting software (ie- ResScan or Encore, etc).

I've never heard of them accepting SleepyHead reports in the past.  Of course, that could change in the future, but we're talking about government agencies here, and we all know the speed at which they operate.   Cool

If you've had success with submitting SleepyHead compliance reports to the FAA, I'd be interested in hearing about the details of how that happened.

FAA does accept Sleepyhead reports, they have for at least the 3+ yrs I've been submitting them.  And they have been accepting for enough years before that to the point that an FAA medical examiner recommended that I, and others, use it.

If a pilot has a diagnosis of OSA and wants to maintain a valid medical, he or she must submit a couple of reports every 12 months.  One is a statement from the treating physician that the CPAP treatment is working, the other is a report from the machine that shows it's actually being used.  The report must show that in the last 12 months >80% of the nights were >6 hrs.  There is no requirement that the reports are generated by any proprietary s/w or by a doctor or DME.  I had used the Devilbiss on-line report generator, but Devilbiss would not generate more than 90 days of data and wouldn't track >6 hr nights, only 4.  So I had to retire that machine when the new FAA reporting requirements were written - they used to be 90 days, then went to 1 yr.

Sleepyhead makes that very simple:  Set the report for 12 months of data and set the compliance hours to 6, then print the report.  It's easy to see that, of the past 365 days, at least 294 of those days were > 6 hrs.  We turn in those two reports every 12 months and are cleared for another year.  There are ways around this reporting requirement, but if you want to do certain things (commercial airline pilot, charter pilot, freight, ag, tossing skydivers, or many other things) then you need to submit these reports annually.
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#2
RE: OSCAR - Open Source CPAP Analysis Reporter
Wow.  That surprises me.  I've always heard from truck drivers that SleepyHead reports were not accepted for CDL purposes, and this is the first time I've heard that the FAA accepts them for pilots.  Perhaps this is dependent upon the individual medical examiner you use for license renewal purposes?

If some FAA medical examiners are accepting them now, I wonder why state CDL licensing authorities won't also accept them?   (or maybe that has changed as well)?

I mean, after all-- FAA private pilot (and definitely commercial) requirements are far more stringent than those required for a CDL.  I know, because my dad was an instrument instructor for many years (1980's to 2008 or so-- I soloed with him back in the late 80's ) and I'm assuming the requirements and required documents have only increased over the years.   

Interesting indeed... Thinking-about
SuperSleeper
Apnea Board Administrator
www.ApneaBoard.com


INFORMATION ON APNEA BOARD FORUMS OR ON APNEABOARD.COM SHOULD NOT BE CONSIDERED AS MEDICAL ADVICE. ALWAYS SEEK THE ADVICE OF A PHYSICIAN BEFORE SEEKING TREATMENT FOR MEDICAL CONDITIONS, INCLUDING SLEEP APNEA. INFORMATION POSTED ON THE APNEA BOARD WEB SITE AND FORUMS ARE PERSONAL OPINION ONLY AND NOT NECESSARILY A STATEMENT OF FACT.


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#3
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 01:28 PM)KSMatthew Wrote:
(03-08-2019, 12:32 PM)SuperSleeper Wrote:
(03-08-2019, 11:51 AM)KSMatthew Wrote: I'll probably load OSCAR and print reports from it and SH to compare side by side.  We use these compliance reports for annual FAA requirements.  FAA requires a 12 month report of compliance data and also requires 6 hrs/night vs 4 that a lot of insurance plans require.

I suspect that OSCAR will be like SleepyHead in that no "official" government agency will accept compliance reports from  anything except "officially sanctioned" proprietary reporting software (ie- ResScan or Encore, etc).

I've never heard of them accepting SleepyHead reports in the past.  Of course, that could change in the future, but we're talking about government agencies here, and we all know the speed at which they operate.   Cool

If you've had success with submitting SleepyHead compliance reports to the FAA, I'd be interested in hearing about the details of how that happened.

FAA does accept Sleepyhead reports, they have for at least the 3+ yrs I've been submitting them.  And they have been accepting for enough years before that to the point that an FAA medical examiner recommended that I, and others, use it.

If a pilot has a diagnosis of OSA and wants to maintain a valid medical, he or she must submit a couple of reports every 12 months.  One is a statement from the treating physician that the CPAP treatment is working, the other is a report from the machine that shows it's actually being used.  The report must show that in the last 12 months >80% of the nights were >6 hrs.  There is no requirement that the reports are generated by any proprietary s/w or by a doctor or DME.  I had used the Devilbiss on-line report generator, but Devilbiss would not generate more than 90 days of data and wouldn't track >6 hr nights, only 4.  So I had to retire that machine when the new FAA reporting requirements were written - they used to be 90 days, then went to 1 yr.

Sleepyhead makes that very simple:  Set the report for 12 months of data and set the compliance hours to 6, then print the report.  It's easy to see that, of the past 365 days, at least 294 of those days were > 6 hrs.  We turn in those two reports every 12 months and are cleared for another year.  There are ways around this reporting requirement, but if you want to do certain things (commercial airline pilot, charter pilot, freight, ag, tossing skydivers, or many other things) then you need to submit these reports annually.

I will make sure OSCAR retains this capability.
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#4
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 01:55 PM)SuperSleeper Wrote: Wow.  That surprises me.  I've always heard from truck drivers that SleepyHead reports were not accepted for CDL purposes, and this is the first time I've heard that the FAA accepts them for pilots.  Perhaps this is dependent upon the individual medical examiner you use for license renewal purposes?

If some FAA medical examiners are accepting them now, I wonder why state CDL licensing authorities won't also accept them?   (or maybe that has changed as well)?

I mean, after all-- FAA private pilot (and definitely commercial) requirements are far more stringent than those required for a CDL.  I know, because my dad was an instrument instructor for many years (1980's to 2008 or so-- I soloed with him back in the late 80's ) and I'm assuming the requirements and required documents have only increased over the years.   

Interesting indeed... Thinking-about

I don't know anything about CDL.  FAA requirements, even though DOT is the "parent" of FAA, are different.  FAA wants it to be easy - if it isn't easy, the temptation to avoid going to a doc for a sleep study is too great.

Any AME (the airman medical examiner) can accept the annual SH report, or whatever s/w was used to generate the report.  Or, you can mail the report directly to FAA. The advantage to going to a local AME for renewal is that you can get renewed on the spot.  The advantage to mailing it to FAA is that you don't have to pay the doctor's fee, but you'll have to wait 2-3 months for them to get back to you and if your OSA paperwork expires during this time you are grounded.  This is just for the OSA renewal portion of the medical, you still need the physical exam on your normal schedule.

About 4-5 years ago FAA tried a different approach to OSA.  Used to be pilots with a new OSA diagnosis were grounded until all the paperwork went through, and wait times are 8-12 weeks.  So pilots were intentionally avoiding getting an OSA diagnosis.  FAA changed things around so that pilots can now fly while the paperwork goes through and simplified matters to try to make it easier for pilots to be proactive in getting checked, treated, and renewed.

FAA now has "Basic Medical" which avoids the need for the reports, but there are some limitations.
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#5
RE: OSCAR - Open Source CPAP Analysis Reporter
KSMatthew

Would you please post an example of the report you use for FAA compliance.  Feel free to redact any personal info.
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#6
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 02:36 PM)bonjour Wrote: KSMatthew

Would you please post an example of the report you use for FAA compliance.  Feel free to redact any personal info.
I just looked at the FAA website - I was wrong about compliance numbers.  I thought they want 80%, they actually want 75%.  So 274 nights out of 365, not 292 nights.  I've always assumed 80%, but since I generally get >95% (I think I miss a week total over the course of a year) it's never an issue for me.

>>>
For CPAP/ BIPAP/ APAP:

A copy of the cumulative annual PAP device report. Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period.
<<<

I don't have a report handy just this minute, but I can explain it.

2 pages:

1) The summary report for the past year.  It will have the compliance numbers printed on it.  How many days total and how may days >6 hrs.  That 6 hrs is key, FAA doesn't want the 4 hrs that most insurance requires.

2) The detail(?) report that shows the histogram of the last 12 months.  I think this report generates several pages of images, but only the page that shows the compliance histogram needs to be turned in.  In my opinion, this page is not required, but in the opinion of at least one FAA medical examiner this page is good insurance that FAA doesn't come back and ask for further info.  It's a quick and easy way for someone to look at a whole year's worth of data and see that 75% of those nights were >6 hrs.  Someone can look at the 6 hr mark on the left side of the graph, then scan across and put a tickmark on all the columns below that level.

Back when CPAPs didn't keep details and just gave you a total number of hours and total number of nights >4 for the previous 90 days, you had to do the math yourself.  Averages would end up skewing the numbers.  For example, 4.1 hrs one night and 9 hrs the next would look like you averaged 6.5 hrs over two compliant nights.  For FAA purposes that is wrong; their number would be 1 night at > 6 out of the last 2.

I know the last sentence of the FAA requirement is confusing: "...average minimum of 6 hours use per sleep period." What they want is, "how many nights were ?6 hrs, and was that number of nights >75% of the last year?"
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#7
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 03:02 PM)KSMatthew Wrote:
(03-08-2019, 02:36 PM)bonjour Wrote: KSMatthew

Would you please post an example of the report you use for FAA compliance.  Feel free to redact any personal info.
I just looked at the FAA website - I was wrong about compliance numbers.  I thought they want 80%, they actually want 75%.  So 274 nights out of 365, not 292 nights.  I've always assumed 80%, but since I generally get >95% (I think I miss a week total over the course of a year) it's never an issue for me.

>>>
For CPAP/ BIPAP/ APAP:

A copy of the cumulative annual PAP device report. Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period.
<<<

I don't have a report handy just this minute, but I can explain it.

2 pages:

1) The summary report for the past year.  It will have the compliance numbers printed on it.  How many days total and how may days >6 hrs.  That 6 hrs is key, FAA doesn't want the 4 hrs that most insurance requires.

2) The detail(?) report that shows the histogram of the last 12 months.  I think this report generates several pages of images, but only the page that shows the compliance histogram needs to be turned in.  In my opinion, this page is not required, but in the opinion of at least one FAA medical examiner this page is good insurance that FAA doesn't come back and ask for further info.  It's a quick and easy way for someone to look at a whole year's worth of data and see that 75% of those nights were >6 hrs.  Someone can look at the 6 hr mark on the left side of the graph, then scan across and put a tickmark on all the columns below that level.

Back when CPAPs didn't keep details and just gave you a total number of hours and total number of nights >4 for the previous 90 days, you had to do the math yourself.  Averages would end up skewing the numbers.  For example, 4.1 hrs one night and 9 hrs the next would look like you averaged 6.5 hrs over two compliant nights.  For FAA purposes that is wrong; their number would be 1 night at > 6 out of the last 2.

I know the last sentence of the FAA requirement is confusing: "...average minimum of 6 hours use per sleep period."  What they want is, "how many nights were ?6 hrs, and was that number of nights >75% of the last year?"

I just added this to our enhancement list, no guarantees.  I still would like to see a copy of what you need, no hurry though

FAA Compliance report per KSMatthew http://www.apneaboard.com/forums/Thread-...ter?page=4
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#8
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 03:38 PM)bonjour Wrote:
(03-08-2019, 03:02 PM)KSMatthew Wrote:
(03-08-2019, 02:36 PM)bonjour Wrote: KSMatthew

Would you please post an example of the report you use for FAA compliance.  Feel free to redact any personal info.
I just looked at the FAA website - I was wrong about compliance numbers.  I thought they want 80%, they actually want 75%.  So 274 nights out of 365, not 292 nights.  I've always assumed 80%, but since I generally get >95% (I think I miss a week total over the course of a year) it's never an issue for me.

>>>
For CPAP/ BIPAP/ APAP:

A copy of the cumulative annual PAP device report. Target goal should show use for at least 75% of sleep periods and an average minimum of 6 hours use per sleep period.
<<<

I don't have a report handy just this minute, but I can explain it.

2 pages:

1) The summary report for the past year.  It will have the compliance numbers printed on it.  How many days total and how may days >6 hrs.  That 6 hrs is key, FAA doesn't want the 4 hrs that most insurance requires.

2) The detail(?) report that shows the histogram of the last 12 months.  I think this report generates several pages of images, but only the page that shows the compliance histogram needs to be turned in.  In my opinion, this page is not required, but in the opinion of at least one FAA medical examiner this page is good insurance that FAA doesn't come back and ask for further info.  It's a quick and easy way for someone to look at a whole year's worth of data and see that 75% of those nights were >6 hrs.  Someone can look at the 6 hr mark on the left side of the graph, then scan across and put a tickmark on all the columns below that level.

Back when CPAPs didn't keep details and just gave you a total number of hours and total number of nights >4 for the previous 90 days, you had to do the math yourself.  Averages would end up skewing the numbers.  For example, 4.1 hrs one night and 9 hrs the next would look like you averaged 6.5 hrs over two compliant nights.  For FAA purposes that is wrong; their number would be 1 night at > 6 out of the last 2.

I know the last sentence of the FAA requirement is confusing: "...average minimum of 6 hours use per sleep period."  What they want is, "how many nights were ?6 hrs, and was that number of nights >75% of the last year?"

I just added this to our enhancement list, no guarantees.  I still would like to see a copy of what you need, no hurry though

FAA Compliance report per KSMatthew http://www.apneaboard.com/forums/Thread-...ter?page=4
Thanks, but I don't know that it needs an "enhancement" unless OSCAR is hardcoded to 4 hrs right now.  As long as I can print a 1 yr report and set compliance minimums to 6 vs 4, I'm good.  SH does support it.  If OSCAR doesn't have a way to set 6 hrs vs 4, then we'll continue to use the final version of SH.

I might have time tonight to attach a report for you.  It's in PDF format and will have to see if I have a way to remove private info.
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#9
RE: OSCAR - Open Source CPAP Analysis Reporter
Other than in preferences I'm not seeing where compliance is set to 6 hrs, and I'd like to check that the % compliance is based on days with less than 6 hours and not an average.
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#10
RE: OSCAR - Open Source CPAP Analysis Reporter
(03-08-2019, 03:59 PM)bonjour Wrote: Other than in preferences I'm not seeing where compliance is set to 6 hrs, and I'd like to check that the % compliance is based on days with less than 6 hours and not an average.

Are you looking at SH or OSCAR?  I'm not familiar with OSCAR yet.

I'll look tonight at the SH settings I use, and also include a copy of the report.  But I think I've covered it:

1) 1 year report.
2) How many nights were >6 hrs?  SH does have a limit that defaults to 4 and can be set to 6.
3) Histogram of that data.

That's pretty much it.  I can't use an average, I need a number.  So it won't work to take total hours over 365/6.  That will give an average hrs/night, but not what I need.  I need to know "how many nights were >6 hrs" in the last 365 days.

This all works OK in SH.
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