HHS OIG Issues Advisory Opinion on Community Paramedicine

HHS OIG Issues Advisory Opinion Permitting Community Paramedicine Program Designed to Limit Hospital Readmissions On March 6, 2019, the HHS Office of the Inspector General (OIG) posted OIG Advisory Opinion 19-03. The opinion related to free, in-home follow-up care offered by a hospital to eligible patients for the purpose of reducing hospital admissions or readmissions. The Requestor was a nonprofit medical center that provides a range of inpatient and outpatient hospital services. The Requestor and an affiliated health care clinic are both part of an integrated health system that operates in three states. The Requestor had previously developed a program to provide free, in-home follow-up care to certain patients with congestive heart failure (CHF) that it has certified to be at higher risk of admission or readmission to a hospital. The Requestor was proposing to expand the program to also include certain patients with chronic obstructive pulmonary disease (COPD). According to the Requestor, the purpose of both its existing program and its proposed expansion was to increase patient compliance with discharge plans, improve patient health, and reduce hospital inpatient admissions and readmissions. Under the existing program, clinical nurses screen patients to determine if they meet certain eligibility criteria. These include...

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Update on New SNF Edits

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing. In a Member Advisory issued last week, the AAA provided an update on a series of new Common Working File (CWF) edits intended to identify ambulance transports furnished in connection with outpatient hospital services that are properly bundled to the skilled nursing facility under the SNF Consolidated Billing regime. These new edits are set to go into effect on April 1, 2019.  In our discussion of the implementation specifics, we attempted to answer the question of what would happen when an ambulance claim is submitted prior to the receipt of the associated hospital outpatient claim, and where the associated hospital claim eventually hit Medicare’s system. Specifically, we indicated as follows: “The Transmittal contains further instructions that the CWF be updated to identify previously rejected ambulance claims upon receipt of an associated hospital claim for the same date of service that contains an Exempted Code.  Once identified, the Shared System Maintainer (SSM) is supposed to adjust the previously rejected or denied ambulance claim.  At this point, the nature of that “adjustment” is...

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CMS SNF Edits Go Into Effect – April 1, 2019

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing On November 2, 2018, the Centers for Medicare and Medicaid Services (CMS) issued Transmittal 2176 (Change Request 10955), which would establish a new series of Common Working File (CWF) edits intended to identify ambulance transports furnished in connection with outpatient hospital services that are properly bundled to the skilled nursing facility under the SNF Consolidated Billing regime. These new edits are set to go into effect on April 1, 2019.  Why these edits are necessary? In 2017, the HHS Office of the Inspector General conducted an investigation of ground ambulance claims that were furnished to Medicare beneficiaries during the first 100 days of a skilled nursing home (SNF) stay. Under the SNF Consolidated Billing regime, SNFs are paid a per diem, case-mix-adjusted amount that is intended to cover all costs incurred on behalf of their residents.  Federal regulations further provide that, with limited exceptions, the SNF’s per diem payment includes medically necessary ambulance transportation provided during the beneficiary’s Part A stay. The OIG’s report was issued in February 2019. The OIG...

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DOL Issues Long-Awaited Proposed Overtime Rule

On March 7, 2019, the United States Department of Labor (USDOL) issued the long-awaited Notice of Proposed Rule Making (NPRM) which proposes changes to the Fair Labor Standards Act (FLSA) overtime provisions.  These proposed changes, which are detail in the 219-page document, follow nearly three years of legal actions challenging the USDOL’s 2016 proposed FLSA overtime changes. A quick history on these proposed changes.  On May 23, 2016, the USDOL issued the 2016 FLSA proposed overtime rule changes that would have more than doubled the minimum salary thresholds for the so called “white collar” overtime exemptions.  Under the 2016 proposed rule, the minimum salary threshold would have increased from $455 per week ($23,660 per year) to $913 per week ($47, 476 per year) and the Highly Compensated Employee (HCE) salary level from $100,000 to $134,000 annually.  Just before the changes were about to become effective, the United States District Court for the Eastern District of Texas invalidated the proposed rule stating that the USDOL lacked the authority to propose these changes.  Shortly thereafter, the proposed changes were put on hold. This latest proposed rule formally rescinds the 2016 proposed rule and would provide for updates to the standard salary level...

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CMS to Host Additional ET3 Model Webinar (3/7)

The Centers for Medicare and Medicaid Services has scheduled an additional webinar on the new Emergency Triage, Treat, and Transport (ET3) Model announced on February 14, 2019. The webinar will be held on Thursday, March 7th at 2:00 PM Eastern. Registration is open. CMS ET3 Model Webinar March 7 | 2:00 PM ET

AAA Webinar Wednesday, March 6: Tools for Billing Services and Other Vendors

Whether you contract with a third-party billing service, or have an internal billing department, the upcoming Ambulance Cost Data Collection (ACE) webinar hosted by the AAA on Wednesday, March 6 is a can’t miss. As we get closer to new Cost Data Collection requirements taking effect across the ambulance service community, the American Ambulance Association has been developing Ambulance Cost Education tools and information to make it easier for services of all sizes and types to report. Billing services and vendors are a key component of the Cost Data Collection process, and if you have not already involved your contracted servicers or employees, this is a great time to start. Tools for Billing Services and Other Vendors, presented by Ambulance Cost Education faculty member Aaron Director, will discuss the web-based reporting tool being developed, and share some ideas for vendors to create an integrated, seamless tool through partnership with the AAA. This is the ideal webinar for vendors that serve the ambulance community, and we encourage you to reach out and share this information broadly.  Invite them to participate and get involved! We know things go better when we work together, and that is why the AAA is working so hard to (more…)

CMS ET3 Model Webinar & Follow Up AAA Member Q&A Call – Wednesday, Feb. 27

The Centers for Medicare and Medicaid Services has scheduled a webinar on the new Emergency Triage, Treat, and Transport (ET3) Model announced on February 14, 2019. The webinar will be held on Wednesday, February 27th at 1:00 PM Eastern. Registration is open. CMS ET3 Model Webinar February 27 | 1:00 PM ET Questions? Have more questions? The AAA is here to help! Following the ET3 Webinar, the AAA will host a Q&A conference call open to all members. AAA Follow Up Q&A February 27 | 3:00 PM ET 1-800-250-2600 Pin: 73556603# Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Rebecca Williamson; AAA Payment Reform Committee Chair, Asbel Montes....

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Release: CMMI Announces Ambulance Innovative Payment Pilot Program

February 14, 2019 For Immediate Release Contact Maria Bianchi American Ambulance Association 202-802-9020 info@ambulance.org CMMI Announces Ambulance Innovative Payment Pilot Program Washington, DC – Today, the Centers for Medicare & Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) announced the launch of the Emergency Triage, Treat and Transport (ET3) Model.  During the next five years, this model will test paying ambulance providers and suppliers when they transport beneficiaries to locations other than an emergency department, if the alternative location is more appropriate medically for the patient.  It will also test paying for health care services provided by qualified health care professionals or through telehealth at the scene even if the ambulance does not transport the patient. While there are several important details yet to be released, this model appears to track the recommendations the American Ambulance Association, our members, and other industry partners have been working with CMS to implement. “Over the last 7 years, the AAA and our members have been working to develop an innovative payment framework to modernize the Medicare ambulance benefit,” said AAA President Aarron Reinert. “We are pleased that CMS is taking this important step and look forward to working closely with Administrator (more…)