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Author: Eric Van Doesburg

Non-Emergency Transport: Avoiding the Fraud Trap [Sponsored]

Written by Eric Van Doesburg on . Posted in Operations, Patient Care, Professional Standards.

By Eric van Doesburg, MP Cloud Technologies
This sponsored post is not endorsed by the American Ambulance Association. It reflects the views of the author.

Did you know that one of the most common practices in our industry could put your company at financial risk? Transporting patients not qualified for ambulance transportation is a hot topic these days as it has heavily contributed to the rise of Medicare fraud cases. This issue has grown even more relevant recently with a case in Florida, where not only was the EMS company found liable of fraud, but it was the first time several hospitals were held culpable as well.¹

While the burden of proof falls on the government to satisfy the statutes in the Federal False Claims Act, the fact is investigators are becoming more aggressive in fighting these types of billing schemes.

“The fact is investigators are becoming more aggressive in fighting these types of billing schemes.”

Yes, there are some bad actors in our industry like any other, but more times than not employees simply may be unaware of the qualifications needed when dispatching non-emergency transport.

Thankfully, a company can protect its financial future simply by having the necessary protocols in place.

For ambulance transportation to be covered by Medicare for a patient, the answer must be “yes” to at least one of the three criteria listed below:

  • “Is the patient bed-confined?”
  • “Does the patient require assistance to get out of bed?”
  • “Is the patient unable to safely sit in a wheelchair for the duration of the transport?”

Dispatchers must ask these specific questions in order to understand the scope of the situation – a step that should be incorporated into your business’ procedures immediately. If it is determined that the patient meets none of the above criteria, then an alternative transportation source must be sought and you have a couple of options.

Non-EMS Transport Options

Rideshare Partnership

Uber™ and Lyft™ have not only affected how we approach transportation as a society but have left a prominent mark on the EMS industry as well. According to a University of Kansas study, the use of ambulance transportation dropped 7% in cities that adopted ride-sharing platforms.² Consider the formation of a partnership with these companies as a low-cost alternative for non-emergency transport that could reduce your liability and develop a sustainable revenue stream for the future without a lot of overhead. Of course, just because the patient may not meet the Medicare criteria for non-emergency transport doesn’t mean that they are in a condition to be able to ride in a car by themselves. This is where the situation can become a little tricky. Is Uber™ or Lyft™ really the bestoption for an elderly person who may have some mild form of dementia and is being released after having a medical episode?

Add Non-Emergency Fleet

As an alternative, another option would be setting up your own fleet of non-emergency transport to cater to your clients’ specific needs. These non-emergency shuttles can ensure a consistent and legal discharge process to keep you in compliance and managing dispatch on your terms. It also allows for a higher level of patient care during the transport than a ride-sharing service can provide.

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With the stakes for fraudulent claims getting higher, you’ll want to make sure you have a protocol in place that protects your business, employees, and clients from any hint of impropriety. However, with the right planning and core systems/partnerships, it will make the process for handling non-emergency transport that much easier… and possibly lead to new revenue channels not available in the past. That’s something we can all get excited about.

¹https://www.modernhealthcare.com/article/20150511/NEWS/150519994

Financial Hardship Policies: Steps for Your Protection [Sponsored]

Written by Eric Van Doesburg on . Posted in Balance Billing.

By Eric van Doesburg, MP Cloud Technologies

In an industry whose sole focus is to help those in need, it’s natural for us to want to assist patients financially when they’re in hardship situations.

Waiving deductibles and copays for patients that have either claimed poverty, or simply for bills that seem too small to make a difference has become common practice. Although this is well-intentioned, it can easily put your company in harm’s way.

“There is no question of if Medicare will audit you, but when.”

The Federal False Claims Act requires businesses to bill patient’s copays and deductibles unless the company puts in place a clearly defined, legally binding policy. Without such a
policy, any actions taken in regard to waiving payments would effectively overbill Medicare, leading to Medicare auditing the company for payment as well as instituting
additional penalties. And in this day and age, there is no question of if Medicare will audit you, but when.

You can still help out the less fortunate while working within the letter of the law, but only with the proper Financial Hardship Policies put into practice. We urge you to seek legal counsel when crafting
and adopting a hardship policy, however, be sure to consider the following points as you get started:

  • Make it clear that you are not offering kickbacks: Clearly state in your guidelines that you do not offer incentives, such as kickbacks, bribes, rebates, or waivers of copayments or deductibles, for anyone bringing your company business.
  • Define your threshold for financial hardship: There is no true definition of financial hardship; every case is different. Most standards suggest waiving copayments and deductibles for patients with a gross family income at or below 200% of the federal poverty guidelines. Your definition should be updated annually to ensure effective practices.
  • Assign a decision-maker: Granting waivers involves state and federal anti-fraud laws, so a compliance officer or administrator would be best suited to assign who is exempt and who is not.
  • Require Documentation: A valid documentation trail is required as evidence for a patient who claims financial hardship, such as W-2 forms, pay stubs, tax returns, or unemployment compensation.

Learn more about MP Cloud Technologies.

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