Every morning, I rattle on about the AMAZING revolution going on – implementation of the ET3 model; the upcoming marriage of telehealth and emergency response; recognition that non-emergency transport of patients to needed appointments has a positive effect on overall health – and non-emergency means more than just ambulance. We truly are evolving from transport to best patient response.

As exciting as this is, my first thought is always, “how will they get paid?” Then my next go-to is, “what will meet documentation standards to receive that money appropriately?”  Fortunately, we have basics in place regarding ambulance – regulatory guidance, and software to document and bill ambulance. We also know what CMS has announced regarding the pilot ET3 program payment for treatment no transport (TNT).

Let’s talk about two important topics – the first is what we know about (but aren’t taking enough advantage of) and second, what topics do we need to monitor for upcoming non-emergency and emergency documentation and payment needs.

Bill NOW for Treatment without Transport

Not all emergency services take advantage of the opportunity to bill now for TNT. Though Medicare has not yet implemented reimbursement, there are payers that can be billed for TNT. Many commercial plans recognize the value of this service. Some Medicaid programs offer reimbursement for TNT (or transport to alternate destinations). However, before billing, there must be a system in place and documentation to support the billing.  As Anne Jensen and Dan Swayze noted in their article, New Mnemonics for Community Paramedics, the assessments and services provided by paramedics who offer CP varies. Given the variations, providers need to have policies that outline what they are doing and what fees are charged. It’s a good time to look at the services you offer, how documentation is done, and set a policy. Before billing anyone, get the ducks in a row. An assessment of where you are and what you currently perform will better prepare your organization for the road ahead.

Monitor closely what happens with telehealth. When an emergency response involves treatment in place, the ET3 model discussed that a partnering health care practitioner would be reimbursed. Where telehealth is used, what will be needed for documentation – for internal use or to be shared? In the ambulance world, there is a joint billing agreement arrangement when two different providers respond to a patient (i.e., BLS transports with ALS from the hospital). Will the requirements be similar for the telehealth provider?  Who will bill Medicare?

This is important - stay in touch with your documentation and billing software vendors. If change is on the horizon, they need to hear from you – what do you need and what do you expect? The vendors are savvy folk; stay tuned to what they say as they can help educate and support your service.

Non-Emergency Arrangements & Partnerships

Non-emergency medical transportation continues to evolve to be more responsive to patient and facility needs with best mode of transport, improved payer relations, more communication with facilities, and innovative partnerships. Rural areas are seeing an uptick in the use of telemedicine to cope with inadequate resources, long transport times, behavioral health matters, and better use of limited ER options. But it’s not easy for NEMT providers to get proper reimbursement.

Our advice is that providers look first at their call process to ensure that the right questions are asked (not MORE questions, but the kind of questions that tell providers what the patient needs help with and who the payer is). If an NEMT company provides service out-of-network, they are unlikely to be paid.

Remember, most patients are seen only one time, while you will deal with a facility every day. It’s a good time to look at your facility contracts. Are they compliant? What about education to your facility partners? Do they know why you ask what you ask and why you need the forms or signatures you request?

Payer interactions are more sophisticated and electronic. Many NEMT services are managed by transport brokers. Whether the request for service is received electronically or by phone, ensure that the service you believe you will provide (e.g., wheelchair van) is the service you have been authorized to perform. There are many “mom and pop” shops across the country. Small can be mighty! But small services suffer more when there are no policies or written procedures to work with payers and follow-up promptly on unpaid bills. Policies don’t have to be elaborate. But do offer guidance for staff on what needs to be documented, how billing will be done and how to follow-up with facilities and payers.

Transports from the ER to a specialized mental health facility is often a non-emergency service. It is advisable that providers focus on how they will partner with payers. Monitor payer arrangements and network and authorization requirements. Remember, behavioral health patients are not always part of the Medicare population. They can be younger and/or Medicaid recipients. Ensure you don’t go unpaid for services rendered.

There are a lot of balls in the air these days. Let us know if we can help!

About the author:  Maggie Adams is the president of EMS Financial Services, with 25 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 provide auditing services, assess their billing for best practices and support their billing and documentation training efforts. “Like” EMS Financial on Facebook, follow us on LinkedIn or for more info, contact Maggie directly at maggie@ems-financial.com or visit www.ems-financial.com