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.
Please see this document from CMS titled “CMS Flexibilities to Fight COVID-19” for more information on transporting to Temporary Expansion Sites, Documentation, Accelerated/Advance Payments, Enrollments, and more.
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:
Several additional requests for waivers have been submitted to Medicare and are retroactive back to March 1, 2020:
- Medicare has approved expansion of the list of covered destinations during the current public health emergency. Ambulance transportation is now covered to all destinations that are equipped to treat the condition of the patient, based on state/local laws where the transport is furnished. This includes alternative sites that are part of a hospital or skilled nursing facility, as well as community mental health, federal qualified health clinic, rural health clinics, physician offices, urgent care facilities, ambulatory surgery centers and any location providing dialysis when an ESRD facility if not available.
This expansion covers both emergency and non-emergency transports however, transports are still required to meet medically necessary. Medicare has been asked to confirm that patients who require isolation meet medical necessity requirements, and we are awaiting an answer.
- Medicare has confirmed that during the public health emergency, patient signatures will not be required.
- Telehealth services are normally provided by practitioners working under the supervision of a physician. Medicare has waived the “direct supervision” requirements during the current public health emergency and is allowing physicians to contract with ambulance agencies, using their personnel to provide telehealth services. The physician would bill for the telehealth services and reimburse the ambulance agency according to contract.
- Still Pending Decision: 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.
- Still Pending Decision: 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.