New SNF PPS Edits Highlight the Importance of Facility Agreements

On April 1, 2019, CMS implemented a new series of Common Working File (CWF) edits that are intended to better identify ground ambulance transports that are furnished in connection with an outpatient hospital service that is properly bundled to the skilled nursing facility (SNF) under the SNF Consolidated Billing regime. These edits work by comparing the ambulance claim to the associated outpatient hospital claim.  Hospital claims were already subject to CWF edits designed to identify outpatient hospital services that should be bundled to the SNF.  These hospital edits operate by referencing a list of Healthcare Common Procedure Coding System (HCPCS) or Current Procedural Terminology (CPT) codes that correspond to outpatient hospital services that are expressly excluded from SNF Consolidated Billing.  Hospital claims for outpatient services that are submitted with one of these excluded codes bypass the existing CWF edits, and are then sent to the appropriate Medicare Administrative Contractor for further editing and payment.  Hospital claims submitted without one of these codes are denied for SNF Consolidated Billing. The new ambulance edits will extend these process one step further.  The ambulance claim will be associated with the outpatient hospital claim on the same date.  To the extent that hospital claim...

This content is available only to AAA members.
Log In or Register

Summary of March 28, 2019 Ambulance ODF

The Centers for Medicare and Medicaid Services (CMS) held its latest Open Door Forum on Wednesday, March 28, 2019.  As with past Open Door Forums, CMS started the call with the following announcements: Ambulance Cost Data Collection – CMS reminded the industry that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, requires CMS to create a new cost data collection system by December 31, 2019. Emergency Triage, Treat, and Transport Model – A representative from the Innovation Center within CMS provided an overview of the “Emergency Triage, Treat, and Transport Model” or “ET3.” This is a 5-year pilot program intended to provide ambulance providers with greater flexibility to handle low-acuity 911 calls, by providing Medicare payment for: (a) ambulance transportation to alternative treatment destinations and (b) treatment at the scene. The CMS representative indicated that CMS is in possession of data that suggests that 16% of emergency ambulance transports to a hospital emergency department could have been resolved by transporting the patient to an alternative treatment site, e.g., an urgent care center. CMS estimates that had all of these patients elected to receive care in the lower-acuity setting, it would have saved the Medicare Program approximately $560 (more…)

The Paycheck Fairness Act

Following many states that have enacted laws geared towards preventing or eliminating inequities in pay between men and women, The Paycheck Fairness Act which was introduced on March 27, 2019, will prohibit employers from asking job applicants about their salary histories or using those histories to base pay or compensation rates.  The Act would require that employers to justify any pay disparities as job-related and would also permit employees to file class action lawsuits based on pay discrimination.  Numerous states around the country have passed laws that prohibit pay history inquiries.   It is strongly recommended that employers conduct a wage analysis to identify any pay disparities between individuals from any of the protected classes performing comparable work....

This content is available only to AAA members.
Log In or Register

New Parents Act Introduced to Provide for Paid Family Leave

On March 27, 2019, Senator Marco Rubio (FL) and Mitt Romney (UT) introduced the New Parents Act which would provide paid parental leave for up to three months by permitting new parents to tap into future Social Security Benefits by either delaying or reducing those benefits later in life.  The Bill also permits new parents to continue to work and use the funds to pay for childcare expenses.  There are several bills that are currently under consideration that provide for paid Family Leave by either postponing Social Security Benefits (The Child Rearing & Development Leave Empowerment Act (CRADLE) and The Family & Medical Insurance Leave Act (FAMILY) which provides for some wage replacement that is funded through a tax on payroll.  These Bills follow numerous state laws recently enacted or currently under consideration around the country to provide a form of paid family and medical leave....

This content is available only to AAA members.
Log In or Register

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...

This content is available only to AAA members.
Log In or Register

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...

This content is available only to AAA members.
Log In or Register

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...

This content is available only to AAA members.
Log In or Register

Mobile Healthcare Branding Toolkit & Webinar

The American Ambulance Association Communications Committee is proud to share with you our first-ever toolkit for ambulance services. This toolkit serves as a guide for ambulance providers and their teams to understand and tell the story of our industry—Mobile Healthcare—with consistency across communication channels. This toolkit provides you with ways to tell your story in a clear, consistent, and engaging manner. Learn: why a new brand was created the true story about the work we do the elements of the new Mobile Healthcare brand how to use messages that communicate positive perceptions of our field how to use brand messages to your audience talking points that you may use and expand for . in your communications   Additional Resources 2019.01.31 Branding Webinar Deck Powerpoint Presentation from January 31, 2019 Webinar Rob Lawrence, Julie Rose, Amanda Riordan “Keeping Your Ambulance Service in the Public Eye” Video Rob Lawrence Sharing Patient Stories Video Rob Lawrence & Matt Zavadsky AAA HIPAA Release Template Marketing tech tips from AAA