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

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 (more…)

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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HHS OCR Requests Feedback on HIPAA Privacy Rule

On January 28, 2019, the Office of Health and Human Services the Office for Civil Rights (HHS OCR) issues a Request for Information (RFI) seeking input from covered entities regarding several aspects of the Health Insurance Portability and Accountability Act (HIPAA).  Specifically, the HHS OCR is seeking input regarding several elements of the Privacy Rule, including the following: Encouraging information-sharing for treatment and care coordination Facilitating parental involvement in care Addressing the opioid crisis and serious mental illness Accounting for disclosures of PHI for treatment, payment, and health care operations as required by the HITECH Act Changing the current requirement for certain providers to make a good faith effort to obtain an acknowledgment of receipt of the Notice of Privacy Practices I am aware that several AAA member services who have struggled with many of the HIPAA restrictions regarding the sharing of PHI with other healthcare entities.  In particular, with regard to individuals who suffer opioid overdoses and efforts to ensure the individual has access to drug treatment programs.  Additionally, HHS OCR is seeking input from covered healthcare providers regarding the “good faith” efforts to obtain acknowledgement of the receipt of Privacy Practices.  This has been a considerable challenge for...

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HIPAA Breach Results in Highest Settlement in OCR History

The U.S. Department of Health and Human Services (HHS) Office of Civil Rights (OCR) announced earlier this month that is has entered into the largest settlement agreement in the history of the Department with Anthem, Inc., the largest Blue Cross and Blue Shield health benefit companies in the country.  Anthem, Inc. agreed to pay $16 million to HHS and take substantial corrective action to settle numerous potential violations of both HIPAA Privacy and Security Rules after it exposed protected health information (PHI) for nearly 79 million people. In March 2015 Anthem filed a breach report with OCR after they discovered that their Information Technology (IT) systems were infiltrated by cyber-attackers who had gained access to their systems after an Anthem employee opened a phishing email.  This email released an undetected continuous persistent threat attack that permitted the cyber-attackers to access their systems from December 2014 through the end of January 2015.  This attack opened access that ultimately resulted in the PHI of nearly 79 million people to be stolen. OCR’s investigation revealed that Anthem failed to conduct an enterprise-wide risk analysis.  Additionally, OCR determined that Anthem “failed to have sufficient policies and procedures to regularly review IT system activity, identify...

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4 Tips: Add Empathy to EMS Care

Empathy is about trying to understand, as best we can, someone else’s situation or experience. The question is, do we in EMS truly understand the word? Are we empathetical to ourselves and to the people we work with? While some say that empathy comes from proper upbringing, today’s decline in civility means we see less and less of it displayed. A major contributing factor is the “tough” exterior we favor in each other: how often have you heard comments like “come on, just suck it up buttercup,” “you need to be tougher than that to be a medic,” or “we’re EMS, we eat our young.” Why are we like this, and why can’t we reinforce the empathy that naturally resides in all of us? Empathy is a big part of our jobs, and we need to teach it to our students, our employees and each other. People need to feel that it’s OK to be empathetic and that it’s a natural part of the whole EMS picture. One of the best techniques to foster empathy is active listening — not only to our patients but also to staff and co-workers. When you actively listen, you H.E.A.R. …  Halt: Stop whatever (more…)

Your EMS Reputation Depends on Three Cs

Your EMS Reputation Depends on Three Cs—Credentials, Courtesy, Community In EMS, your reputation is critical. Your character moves with you from provider to provider and from squad to squad; EMS is a small world where people know about you before you even step foot in the door. People react to you based on judgments from not only real life, but also your digital life. With Facebook, Snapchat, Instagram and other social media networks so prevalent today, your social media profile serves as the basis of your reputation both professionally and privately. Unfortunately, social media blunders abound among EMS providers, affecting their reputations and their future hiring ability. You can find hundreds of examples doing a quick online search; here are just two. Three South Carolina responders fired for making statements like “idiots shutting down I-126. Better not be there when I get off work …” (Kaplan, 2016, para. 3) A Brockton, Mass. dispatcher who said of a pregnant overdose patient, “She needs to be left to rot …” (Shephard, 2018, para. 5) A better way to think of your reputation is the “Three Cs” — Credentials, Courtesy and Community. Credentials may also be called Continuing Education, as it’s vital to...

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Make a Difference: EMS and Human Trafficking

When we think of trafficking, we generally think of drugs or weapons, not human beings. Yet the problem exists in numerous communities where EMS responders deliver care. Human trafficking is defined by the United Nations as “the recruitment, transportation, transfer, harboring, or receipt of persons by improper means for an improper purpose.” (End Slavery Now, 2018, para. 1) A more succinct definition comes from Kathryn Brinsfield, MD, MPH, Assistant Secretary for Health Affairs and Chief Medical Officer for the Department of Homeland Security: “Human trafficking is modern-day slavery.” (DHS, 2017, para. 3) Why is this so important in today’s EMS field? We are the first on scene, we are the ones invited inside where others are not and we are the ones who see an injured person’s environment.  Our interactions with others can help us spot some of the tell-tale indicators. Unfortunately, there are many reasons people are trafficked: Domestic Slavery: People are brought into private homes to work as slave labor, with no options to leave. Sex Trafficking: Children, men and women are forced into the commercial sex industry Forced and Bonded Labor: People are forced to work under the threat of violence for no pay — often to repay (more…)