Ambulance Open Door Forum, April 22, H.R. 2

CMS held its latest Ambulance Open Door Forum on April 22. It started with the following two announcements:

– H.R. 2 was signed into law extending the temporary ambulance adjustments through December 31, 2017. The adjustments are 2% (urban pick-ups), 3% (rural) and 22.6% (super rural).

– For free standing facilities, use the “P” modifier if the facility is not part of the hospital and use “H” if it is hospital-based.
Following these announcements, there was a Question and Answer period. Most of the questions were not answered on the call and the caller was asked to submit their questions to CMS, or was told to ask their Medicare Administrative Contractor or was told to appeal the denied claim referenced in their question. A few were answered, as follows:

– Hospice – it is best to verify the eligibility for Part B versus hospice benefits, before submitting claims to Part B to avoid audits that take back payments for claims that should have been billed to the hospice.

– a question asked who to bill if a patient is transported from the free standing ER to the hospital and the facilities have the same ID number. The caller was told to bill the hospital. NOTE: The caller did not provide all of the facts, e.g. whether they are on the same campus, whether the patient was treated and released vs. admitted at the hospital, etc. Thus, the answer is only correct for certain circumstances.

– one MAC is denying mileage for air ambulance claims based on an edit where the MAC only allows 30 units for air ambulance and most air transports are more than 30 miles. Such denials would have to be appealed showing the additional mileage was to the nearest appropriate facility.

– a patient is transported by air ambulance and then by ground. The caller wanted to know if the PCS for the ground ambulance could be used for the air component. The answer was that it is left up to the MAC. However, note, air ambulance is covered for emergencies and if the air component was an emergency, no PCS would be needed.

– if the patient is transported from the free-standing ED to the hospital, the caller was told to bill Part B. However, if the patient was admitted as an in-patient by the hospital before the ambulance transport began, then the admitting hospital is responsible for the ambulance transport as the ambulance transport would have occurred while the patient was an in-patient at that hospital.

– free-standing ED transport to a hospital ED where they are treated and released – – bill Part B.

– a caller asked how CMS will handle condition codes when ICD-10 codes are implemented. They were told to check the CMS web site for ICD-10 codes. NOTE: The A.A.A. will be publishing more information on this issue, with a crosswalk.

The next Ambulance Open Door Forum will be June 17, 2015.

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H.R. 2, ICD-10, Medicare Ambulance Relief


David Werfel

David Werfel is a partner at Werfel & Werfel, PLLC.