Fall and spring are conference seasons! It’s that time of year when ambulance associations and industry organizations hold their events. Today I will tell you about a couple questions that I get asked repeatedly when I’m speaking. We will outline ideas of what you can do and where you can go for help on these issues. Some of the things I get asked are oldies, but goodies (like ALS documentation questions or facilities who won’t pay or won’t sign needed documents) while other questions concern more recent concerns like the expansion of the prior authorization program. Here goes:

Facilities

Facilities are a perpetual problem whether you do emergencies or non-emergencies. If you do emergencies the challenge is getting signatures – facility staff worry about signing because of HIPAA or because of concern of financial responsibility. That's an educational outreach effort that you need to do. Make sure that you talk to facilities about why you need what you need. From a non-emergency perspective, the biggest issue here is that the facilities do not want to pay you a decent rate for service or the facilities do not pay you in a timely manner. There two steps you can take your Step #1 is education Step, #2 escalation.

Education means that you get to the proper people within the facility and you get them the OIG opinions on discounting and on prompt pay. Those OIG opinions are readily available – email us if you need them – and they will help the facility understand why you need to be paid a reasonable rate. The next thing you can do if you are having trouble with your facilities is to escalate. We recommend that you find out who the compliance officer is of the facility (or go to the corporate center of the facility organization). Compliance officers are very responsive to regulatory issues.  Last but not least, check the Medicare Claims Processing Manual, Chapter 15, section 30 and check the Medicare Benefits Policy Manual Chapter 10 for information on the types of services that nursing homes and hospitals are supposed to pay.

Finally, make forms easier to you and them. Give your facilities a stack of your signature forms with lifetime signature language. The facility can then put the signature form into their packet of forms for new patients entering the facility. The facility staff can get a signature at the time the patient checked into the facility.

 

ALS Billing

The OIG mid-year work plan continues to target emergency ALS transports. We’ve recently told you that CMS identified $226 million in overpayments for ALS-1 Emergencies. Emergencies are on the radar as well as dialysis transports. This means if you perform ALS emergencies you have to make sure you are doing things the right way. A great tool to use to look at when you bill ALS versus BLS is available at CMS. Click here for the list of Ambulance Condition Codes which provides a good breakdown of signs and symptoms that differentiate an ALS call from a BLS call. This tool can also be helpful for documentation.

We also urge you to perform internal review to see that you were billing for ALS assessment properly and that you are doing ALS documentation correctly. It is best to have a good QA program in place to review documentation BEFORE it goes to billing. That means having an operational supervisor or manager look at trip reports.

If you perform hospital to hospital transports, remember that they more likely to be non-emergency than emergency.  We see many, many hospital to hospital trips billed as ALS emergency in error.  It’s okay to bill emergency IF you met the emergency guidelines.

Prior Authorizations

Should you be worried about prior authorizations? Yes, you should be worried if you do dialysis transports. It is not yet known if CMS will roll out the prior authorization process across the country effective January 1, 2017. However, it's a good idea to be prepared.

The prior authorization process went into effect as a pilot program in Pennsylvania, South Carolina and New Jersey effective December 2014. Things were rocky at the start (that's an understatement) but efforts were made by providers and ambulance associations in those states and many of the problems improved. I didn't say it was perfect; I said they improved. In fact, CMS is very proud of the fact that they received over 18,000 requests for prior authorization and they only granted 6000-some requests in that first year.

The program was rolled out to additional states in 2016. The original thought was that the whole country will deal with this effective 2017; that plan has yet to be confirmed.  The best thing you can do about this topic is stay informed. Check the Medicare website for information on prior authorization requirements that are already in place. That will give you a feel for what you can expect.  Check Novitas, the first Medicare contractor to put this into play. Their website has information on the submission process of prior authorization. It would be a good idea to familiarize yourself with expectations and document requirements. The American Ambulance Association has presented webinars on this topic (Brian Werfel is on top of the latest info). Other state associations are staying tuned to the issue. Monitor your email alerts for information and educational opportunities.

Let us know if we can help!

About the author:  Maggie Adams is the president of EMS Financial Services, with over 20 years’ experience in the ambulance industry as a business owner and reimbursement and compliance consultant. Known for a practical approach and winning presentation style, Maggie has worked with medical transportation providers and billing companies of all kinds to support their billing, auditing, and documentation training efforts. Check out our newest documentation training webinars and billing webinars on our website.Friend EMS Financial on Facebook, or for more info, contact Maggie directly at maggie@ems-financial.com or visit www.ems-financial.com