Dear Systems Design West clients,
All of us at SDW are so grateful for your service to our communities during these times that previously were impossible to imagine. We are proud to support you and do all that we can to make sure your organization has its revenue and backend patient care well in-hand.
There are many new programs, acts, laws, and discussions aimed at helping seemingly everyone, including ambulance providers, weather this storm. This communication is meant to highlight some elements of recent changes to make you aware of what could be impactful to ambulance providers.
Coronavirus Aid, Relief, and Economic Security (CARES) Act as related to EMS:
Suspends Medicare sequestration, meaning a 2% increase in Medicare payments, beginning with May 1st dates of service through Dec 31, 2020
Suspends prior authorization requirements for Medicare; individual states may choose to adopt this waiver and change prior authorization standards for their Medicaid programs
As a blanket waiver, some Medicare enrollment requirements have been loosened or expedited for providers.
Medicare is also creating an avenue where providers enrolled with CMS can access Accelerated and Advanced Payments. Please go here for more information: https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf
Several additional requests for waivers have been submitted to Medicare and our understanding is that these are currently pending a decision:
Allow for payment of transports to alternative destinations, such as primary care, urgent care, mental health facilities and COVID-19 sites. This waiver has been requested for both emergency and non-emergency transports. If approved, good documentation about WHY the alternative destination was necessary will be required.
Allow for payment of Treat, No Transport/Treatment in Place. AAA requested this waiver on March 11th and while Medicare initially responded that they do not believe they have the authority to allow payment of non-transports, the request is still pending.
Waive patient signature requirements for ambulance suppliers. Many of you have asked about patients signing the Billing Authorization form, either on a tablet or on paper, and the associated infection control problems. While this requested waiver is pending, you can access recent guidance (https://www.pwwemslaw.com/sites/default/files/forms/pww-covid-19-ems-resources/pww-statement-assignment-benefits-signatures-ems-practitioners.pdf) on how documentation might describe suspected COVID 19 patients who are physically or mentally incapable of signing.
Allow transport of suspected or confirmed COVID patients to meet ambulance medical necessity.
Each State’s Medicaid office is having its own discussions on what can be done at this time. For example, in WA there is discussion of increasing the fee schedule and expanding requirements on the existing Treat-and-Refer program. It may take time for any changes to materialize, however we are tracking closely.
One key theme we have gleaned is that good documentation and cost tracking is critical to accessing other emergency funds. We encourage our clients to review the FEMA Category B Emergency Protective Measures Public Assistance Program to see what costs FEMA funds may cover. For clients selected for the first year of Medicare Cost Data Collection, there may be revisions to the cost report to account for costs incurred because of this crisis. Again, good documentation and cost tracking of all coronavirus activities is encouraged.
Good documentation will also be needed in any patient care report where the patient is suspected or confirmed to have COVID-19. We will be tracking these claims through the billing process and using all approved waivers to correctly bill, receive payment and appeal denials. The report needs to clearly document an impression or assessment of COVID-19 and the associated signs and symptoms. This information greatly improves our ability to collect payment.