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As mentioned in our March newsletter, Medicare was considering payment for non-transports, in limited situations. That possibility has now become a reality, as HHS recently implemented a COVID waiver allowing Medicare payment for select non-transports.

While this is good news for ambulance providers, the new COVID waiver is a temporary benefit, only allowed during the public health emergency. The waiver is also limited to those patients who would have been transported but no transport occurred based on local EMS COVID protocols designed to reduce the number of transports to hospitals. CMS has issued a Fact Sheet on this non-transport service, call Treatment in Place (TIP).

If your agency is interested in billing for Treatment in Place, the first step is to review your EMS COVID protocols that specify when patients should not be transported and instead receive treatment at the response location. The protocol should describe under what situations you are required to treat the patient in place and not transport.

If you do not have any protocols that meet this requirement, one could be implemented now and any subsequent non-transports specific to that protocol could be payable. You are not required to create a COVID protocol—you can continue to treat patients in place and not submit claims to Medicare for payment.

For those agencies that have treated patients in place according to a COVID protocol and would like to bill Medicare, you will need to identify these services and forward the incidents to Systems Design for billing. Here are the details to review:

  • Qualifying dates of service begin on March 1st, 2020, if you had a COVID EMS protocol in place on that date. If your COVID protocol is dated later than March 1st, 2020, then the protocol date is your start date. The end date will be the date the public health emergency ends.
  • The call must come through 911 or something equivalent.

•     The documentation will need to show that if the patient had been transported, the transport would have met medical necessity, i.e., any other means of transportation would have endangered the patient’s health.

•     Patient is a Medicare or Medicare HMO patient.

Insurance information might not have been documented for these patients. Most patients with Medicare coverage are 65 and over, so you could screen by patient’s age. Systems Design can screen for insurance for a small Eligibility Review fee.

If you have eligible services under TIP for SDW to bill, some updates may be needed to your current billing export process, especially if you do not usually send non-transports. Please contact imports@sdwems.com to insure we receive the appropriate incidents and can identify the service as covered under the temporary waiver.

There is no requirement to establish a specific fee for Treatment in Place services. Medicare allows billing at the appropriate BLS or ALS level, depending on the care the patient received.  

As you can see, this waiver can be complex and is limited in scope. Some services, such as lift assist and patient refusal, will not qualify as billable Treatment in Place services. Please contact admin@sdwems.com or 800-585-5242 if you have any questions regarding this new Medicare covered service.