Government Affairs Archives - Page 17 of 17 - American Ambulance Association

Senate Delays Vote on SGR Repeal Package

Written by Michael Hall on March 27, 2015. Posted in Government Affairs, Legislative, Medicare, Member Advisories, Reimbursement.

Early this morning after completing action on a FY 2016 Senate Budget Resolution, Senate Majority Leader Mitch McConnell (R-KY) announced that the Senate would not act on legislation (H.R. 2) to permanently repeal the sustainable growth rate (SGR) formula for physicians until after the Easter recess. H.R. 2 includes the 33-month extension of the temporary Medicare ambulance increases. Senate Majority Leader McConnell had sought consideration today of H.R. 2 under unanimous consent which requires the support of all 100 Senators. There were objections to the expedited vote and thus the Senate is now expected to consider the bill when it returns on April 14.

The temporary Medicare ambulance increases expire on March 31. However, contractors have a standard requirement to hold all Medicare claims for 14 days before making payment. The Centers of Medicare and Medicaid Services (CMS) has issued a notice to contractors formally directing them to utilize this hold. So if the Senate does complete action on H.R. 2 on April 14 there will be no need for reprocessing any claims for the retroactive increases. Should action on H.R. 2 be delayed further, Congress could do a short-term extension or simply allow the provisions to expire for a short period of time. Senate Majority Leader Mitch McConnell and Senate Minority Leader Harry Reid (D-NV) have both stated they would like quick consideration of H.R. 2 when the Senate returns.

We will continue to keep you posted of new developments.

House Votes in Favor of Permanent Doc Fix, Bill Moves to the Senate

Written by Michael Hall on March 26, 2015. Posted in Government Affairs, Legislative, Medicare, Member Advisories, Regulatory, Reimbursement.

Earlier today, the U.S. House of Representatives voted in favor of H.R. 2, doing away with Medicare’s sustainable growth-rate formula and passing a permanent doc fix. The 392-37 vote was overwhelmingly bipartisan. As we reported on March 24, thanks to our champions on Capitol Hill, a 33-month extension of the temporary Medicare ambulance increases was included in the bill. If enacted, the bill would extend the deadline for expiration of Medicare ambulance relief from March 31 until December 31, 2017.

The Senate still needs to pass the bill and is working on a short time-line before they adjourn for recess. Senate Republicans and Democrats have expressed concerns about different aspects of the bill so it is unclear whether the chamber will consider H.R. 2 before it recesses. It is also uncertain if Congress would pass a short-term extension to give the Senate more time or if CMS would be required to formalize its 14-day claim hold policy should H.R. 2 not be enacted before March 31.

In addition to Medicare ambulance relief, the package also includes language from the Protecting Integrity of Medicare Act (H.R. 1021) expanding the current prior authorization pilot programs on repetitive BLS non-emergency ambulance transports in South Carolina, Pennsylvania and New Jersey. Starting in January 2016, the bill would expand the programs to Delaware, DC, Maryland, North Carolina, West Virginia and Virginia. The program would then expand nationwide starting in January 2017.

The AAA will continue to push for the Medicare Ambulance Access, Fraud Prevention and Reform Act (S. 377, H.R. 745). S. 377 and H.R. 745 would make the current temporary ambulance increases permanent and place our industry in a strong position moving forward for data-driven reforms to the ambulance fee schedule. S. 377 and H.R. 745 would also address fraud and abuse with repetitive BLS non-emergency dialysis transports. While a similar program to the current pilot programs. The prior authorization within S. 377 and H.R. 745 would apply only to dialysis transports and would institute additional safeguards to ensure timely prior authorization for medically necessary transports.

I want to thank all AAA members, staff and consultants who continue to work tirelessly on extending essential Medicare ambulance relief. We will keep you posted of new developments.

House SGR Repeal Package Contains Ambulance Relief Extension

Written by Michael Hall on March 24, 2015. Posted in Government Affairs, Legislative, Medicare, Member Advisories, Regulatory, Reimbursement.

Earlier today, House Republican and Democratic leadership released the complete package (H.R. 2) for a permanent fix to the physician fee schedule. I am happy to report that the AAA through our champions on Capitol Hill was successful in getting a 33-month extension of the temporary Medicare ambulance increases included in the bill. If enacted, the bill would extend the deadline for expiration of Medicare ambulance relief from March 31 until December 31, 2017.

The House is scheduled to consider H.R. 2 on either Thursday or Friday prior to adjourning for the two-week Easter recess. The bill is currently expected to pass the House with bipartisan support. Senate Republicans and Democrats have expressed concerns about different aspects of the bill so it is unclear whether the chamber will consider H.R. 2 before it recesses. It is also unclear if Congress would pass a short-term extension to give the Senate more time or if CMS would be required to formalize its 14-day claim hold policy should H.R. 2 not be enacted before March 31.

The package also includes language from the Protecting Integrity of Medicare Act (H.R. 1021) expanding the current prior authorization pilot programs on repetitive BLS non-emergency ambulance transports in South Carolina, Pennsylvania and New Jersey. Starting in January 2016, the bill would expand the programs to Delaware, DC, Maryland, North Carolina, West Virginia and Virginia. The program would then expand nationwide starting in January 2017.

The AAA continues to push for the Medicare Ambulance Access, Fraud Prevention and Reform Act (S. 377, H.R. 745). S. 377 and H.R. 745 would make the current temporary Medicare ambulance increases permanent and place our industry in a strong position moving forward for data-driven reforms to the ambulance fee schedule. S. 377 and H.R. 745 would also address fraud and abuse with repetitive BLS non-emergency dialysis transports. While a similar program to the current pilot programs, the prior authorization within S. 377 and H.R. 745 would apply only to dialysis transports and would institute additional safeguards to ensure timely prior authorization for medically necessary transports.

We will keep you posted of new developments.

Advocate for Permanent Medicare Ambulance Relief

Written by Michael Hall on February 6, 2015. Posted in Government Affairs, Legislative, Medicare, Regulatory, Reimbursement.

The U.S. House of Representatives is currently developing a package on a permanent fix to the physician fee schedule. House Speaker John Boehner recently announced the effort for a permanent fix instead of another extension and the framework of a package is coming together quickly. It is therefore critical that you contact your members of Congress today in support of permanent ambulance relief.

Permanent Medicare Ambulance Relief Bills Introduced in Congress

Written by Michael Hall on February 6, 2015. Posted in Government Affairs, Legislative, Medicare, Member Advisories, Reimbursement.

I am extremely happy to report our Senate and House champions on Medicare ambulance relief introduced on Wednesday the Medicare Ambulance Access, Fraud Prevention, and Reform Act of 2015 (S. 377, H.R. 745). Senators Charles Schumer (D-NY), Pat Roberts (R-KS), Patrick Leahy (D-VT) and Susan Collins (R-ME) introduced the Senate bill (S. 377) and Congressmen Greg Walden (R-OR), Peter Welch (D-VT), Devin Nunes (R-CA) and Richard Neal (D-MA) introduced the House bill (H.R. 745).

Prior Authorization Issues – South Carolina

Written by David Werfel on January 12, 2015. Posted in Government Affairs, Medicare, Regulatory, Reimbursement.

Based on implementation issues involving the Prior Authorization program for repetitive patients inSouth Carolina, Brian and I had a conference call with representatives of CMS and Palmetto on Friday January 9, 2015. Three main issues were discussed, as follows:

1. Legal Representative Payee – There was confusion concerning repetitive patients that had a Legal Representative Payee. These are patients who can not conduct their own affairs and have a form on file at the Social Security Administration for someone else to be their legal representative. When ambulance companies submitted for Prior Authorization for these patients, they were told thePrior Authorization did not apply for the patient. Palmetto posted their policy for these patients on their web site.

Unfortunately, you will not know right away which patients have a legal representative payee. Most likely you will not know until you receive a rejection of the Prior Authorization request. Therefore, until you have been told a repetitive patient has a legal representative payee, file with Palmetto for the priorauthorization.

Once you are told the patient has a legal representative payee, then submit claims, just as you would for non-repetitive patients, i.e. do not continue to try to obtain prior approval or a Unique Transaction Number (UTN).

We have asked Palmetto if there is a database that you can access before going through the priorauthorization process. So far, there is not, but they are checking on this issue.

FYI, this was a policy instituted by CMS for the Prior Authorization process based on other programs (not ambulance) they have in place.

2. Incorrect Edit for Non-Repetitive Patients – On Wednesday, January 7th, we advised Palmetto that claims for non-repetitive patients were either being denied or that they needed further development as there is a systems edit that is pulling patients who had multiple transports over a period of time, but are not supposed to be in this Prior Authorization program. For example, a patient who has had four hospital discharges following illnesses for a fracture, a CVA, pneumonia and surgery, is not “repetitive”, for Prior Authorization purposes. On the conference call on Friday, Palmetto and CMS agreed with our assessment of the situation. They indicated that not only has the cause of the problem been identified, but they believe that it will be fixed in approximately one week. They are testing it now. They are looking at January 19 as the date for the “fix” to be implemented.

They have located 485 claims in this status that are currently “suspended”. When the “fix” is implemented, they will release these claims for processing, i.e. those providers should not resubmit the claims as Palmetto will do it automatically. Claims for these non-repetitive patients that have already been rejected should be resubmitted.

NOTE: Novitas is having the same problem. They sent out a notice to providers in their jurisdiction advising them they are aware of the problem. We assume that the same “fix” will be tried by Novitas.

3. Common Errors – We asked Palmetto if they could come up with a list of the common errors being made by ambulance companies. Following the conference call, they provided us with the list below. Providers in South Carolina (as well as in New Jersey and Pennsylvania, even though NJ and PA submit to Novitas) should review the list to ensure you are not making these mistakes:

– The PCS submitted does not have a valid signature date.

– The date of the signature is post- dated, perhaps to match a future date the patient will be starting.

– The signature on the PCS is not identifiable. The name of the physician must be identifiable. This does not mean the signature itself must be legible, it means that Palmetto has to be able to read the name of the physician that signed the PCS.

– The PCS has been amended (e.g. to print or type the name of the physician) without any notation by the amending individual. Any amendments/additional information should be clearly signed or initialed and dated by the person making the change or note.

– Submission of contradictory documentation. For instance, the PCS may support the transport, but the supporting documentation from the certifying physician does not.

– If the Prior Authorization is approved, the UTN is not entered into the appropriate field or submitted at all.

– For claims that are non-emergent, non-repetitive, providers are listing something (e.g. “N/A” or “not a PA” or “non-repetitive”) in the UTN field. For these non-repetitive patients, do not put anything the UTN field. The edit for the prior authorization is hard coded. Therefore, if their computer finds anything in this field, for patients who do not have prior authorization, the claim will reject.

Palmetto indicated that they will have a conference call with ambulance providers to discuss “hot issues”, including those above. At this time, they are looking to have that conference call on January 19th, although that is subject to change. For those affected, check the Palmetto web site and otherwise look for the notice for this conference call.

Finally, implementing a program of this nature is always going to have some start-up problems. Now that the two issues noted in #1 and #2 above have been identified and are about to be resolved, the remaining problems, such as those noted in #3 above, are mostly left up to the providers to understand what is needed, where the information is to be listed, etc. Once that is understood, the process will work smoothly as it did for many years in Ohio, when Palmetto and its predecessor used a prior authorization process for ambulance transports of non-emergency dialysis patients.

Of course, there will always be those situations where you believe medical necessity is met, but Palmetto does not agree. In those situations you will have to decide if more information is needed, whether you agree with Palmetto and the patient can be transported via wheelchair van, whether you need to advise the patient/facility accordingly, whether to accept the denial or whether to appeal.