Grants and Tax Credits Toolkit

Grants and Tax Credits Toolkit Download materials from Akin Gump including aid summaries and how-to guides on qualifying for tax credits and deferments and applying for financial assistance. Paycheck Protection Provision Loans Summary Five Steps to an SBA PPP Loan Five Steps to Getting a Self-Employed Paycheck Protection Plan (PPP) Loan Five Steps to Claim…

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CMS: Medical Necessity & Patient Signature Requirements During COVID-19

CMS Clarifies Medicare Requirements Related to Medical Necessity and the Patient Signature Requirement during Current National State of Emergency By Brian S. Werfel, Esq. On April 9, 2020, CMS updated its Frequently Asked Questions (FAQs) for billing Medicare Fee-For-Service Claims during the current national state of emergency.  This document includes guidance for numerous industry types,…

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2020 Medicare Reference Manual & Medicare Update Webinar

The 2020 Medicare Reference Manual and the 2020 Medicare Update Webinar are both available for purchase. Please see details below!

2020 Medicare Update Webinar

Thursday, April 30, 2020 | 2:00pm EST
Presenter: Brian Werfel, Esq.
$99 for AAA-Members | $198 for Non-Members

Join A.A.A. Medicare Consultant Brian S. Werfel, Esq. for an update on recent changes to Medicare’s coverage of ambulance services. This webinar coincides with the American Ambulance Association’s release of its 2020 Medicare Reference Manual. Brian will discuss recent changes in Medicare policy, including changes to the rules governing the enforcement of fraud and abuse, the appeals process, etc. We will also discuss Medicare’s proposed plan for the ET3 Program, the national expansion of the prior authorization model for scheduled non-emergency transports, and much more.

Of course, we will also discuss Medicare’s coverage of ambulance services during the current COVID-19 process. This will include a frank discussion of the issues related to medical necessity for the transportation of known or suspected COVID-19 patients, the coverage of transports to field hospitals and other alternative destinations, the current status of certain administrative rules like the Medicare patient signature requirement and the Notice of Privacy Practices, etc.

The session will include an extended Q&A period to address any and all questions from attendees. Purchase Webinar► 

*2020 Medicare Reference Manual Sold Separately* 

 

2020 Medicare Reference Manual 

$200 for AAA-Members | $400 for Non-Members
By David Werfel, Esq & Brian Werfel, Esq

The American Ambulance Association’s 2020 Medicare Reference Manual is a must-have for ambulance services that bill Medicare for transports.

2% Payment Adjustment Suspended (Sequestration)

Medicare FFS Claims: 2% Payment Adjustment Suspended (Sequestration)

Section 3709 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act temporarily suspends the 2% payment adjustment currently applied to all Medicare Fee-For-Service (FFS) claims due to sequestration. The suspension is effective for claims with dates of service from May 1 through December 31, 2020.

HHS Announces Release of Initial Tranche of CARES Act Provider Relief Funding

On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).  As part of that Act, Congress allocated $100 billion to the creation of a “CARES Act Provider Relief Fund,” which will be used to support hospitals and other healthcare providers on the front lines of the…

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COVID-19 Relief Payments Begin Today

AAA ADVOCATES FOR COVID-19 RELIEF FOR AMBULANCE SERVICES COVID-19 Relief Payments Begin Today Beginning today, ambulance service suppliers and providers should start automatically receiving an allocation of payments from the Public Health and Social Emergency Fund. According to the Department of Health and Human Services (HHS), an initial distribution of $30 billion of the funds…

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CMS Announces Delay to ET3 Start Date

On April 8, 2020, the Centers for Medicare and Medicaid Services (CMS) announced that it will be delaying the start of the Emergency Triage, Treat and Transport (ET3) Model until Fall 2020.  The ET3 Model was previously set to start on May 1, 2020.  CMS cited the national response to the COVID-19 pandemic as the…

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EMS Agencies Can Take Advantage of Accelerated or Advanced Payment Opportunities from CMS

The Centers for Medicare and Medicaid Services (CMS) has expanded the Accelerated and Advance Payment Program to a broader group of Medicare Part A providers and Part B suppliers in an effort to provide financial relief and to increase cash flow to providers of services and suppliers impacted by the 2019 Novel Coronavirus (COVID-19) pandemic….

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Accelerated Payment Program Highlights

CMS announced at the end of last week that it is expanding its Accelerated Payment Program.  The goal of the program is to address cash flow problems arising from the public health emergency.  The program functions as a short-term loan with no interest. To qualify for advance/accelerated payments the provider/supplier must: (1) Have billed Medicare for claims…

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Trump Administration Provides Financial Relief for Medicare Providers

FOR IMMEDIATE RELEASE
March 28, 2020

Contact: CMS Media Relations
(202) 690-6145 | CMS Media Inquiries

Trump Administration Provides Financial Relief for Medicare Providers

Action comes to aid providers and suppliers facing challenges in responding to COVID-19 pandemic

Under the President’s leadership, the Centers for Medicare & Medicaid Services (CMS) is announcing an expansion of its accelerated and advance payment program for Medicare participating health care providers and suppliers, to ensure they have the resources needed to combat the 2019 Novel Coronavirus (COVID-19). This program expansion, which includes changes from the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, is one way that CMS is working to lessen the financial hardships of providers facing extraordinary challenges related to the COVID-19 pandemic, and ensures the nation’s providers can focus on patient care. There has been significant disruption to the healthcare industry, with providers being asked to delay non-essential surgeries and procedures, other healthcare staff unable to work due to childcare demands, and disruption to billing, among the challenges related to the pandemic.

“With our nation’s health care providers on the front lines in the fight against COVID-19, dollars and cents shouldn’t be adding to their worries,” said CMS Administrator Seema Verma. “Unfortunately, the major disruptions to the healthcare system caused by COVID-19 are a significant financial burden on providers. Today’s action will ensure that they have the resources they need to maintain their all-important focus on patient care during the pandemic.”

Medicare provides coverage for 37.4 million beneficiaries in its Fee for Service (FFS) program, and made $414.7 billion in direct payments to providers during 2019.  This effort is part of the Trump Administration’s White House Coronavirus Task Force effort to combat the spread of COVID-19 through a whole-of-America approach, with a focus on strengthening and leveraging public-private relationships.

Accelerated and advance Medicare payments provide emergency funding and addresses cash flow issues based on historical payments when there is disruption in claims submission and/or claims processing. These expedited payments are typically offered in natural disasters to accelerate cash flow to the impacted health care providers and suppliers. In this situation, CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19.  The payments can be requested by hospitals, doctors, durable medical equipment suppliers and other Medicare Part A and Part B providers and suppliers.

To qualify for accelerated or advance payments, the provider or supplier must:

  • Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form,
  • Not be in bankruptcy,
  • Not be under active medical review or program integrity investigation, and
  • Not have any outstanding delinquent Medicare overpayments.

Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately. CMS anticipates that the payments will be issued within seven days of the provider’s request.

An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here: www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf

This action, and earlier CMS actions in response to COVID-19, are part of the ongoing White House Coronavirus Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, visit www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.

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Get CMS news at cms.gov/newsroom, sign up for CMS news via email and follow CMS on Twitter CMS Administrator @SeemaCMS@CMSgov, and @CMSgovPress. 

Webinar Materials & FAQ: Claims Guidance for COVID-19

Webinar: How to Best Document and Track Claims Related to COVID-19

Recorded: Thursday, March 26th | 12:00pm Eastern
View On-Demand Recording
View PPT Slides

FAQ of unanswered webinar questions:

  1. Is the idea that the ET3 model will be pushed to all ambulance companies or only previously selected participants?

The request into CMS and leadership during the declared public health emergency is to allow all ambulance providers and suppliers to transport patients or treat in place based upon the concepts outlined in the Emergency Triage, Treatment and Transport model as defined by CMMI’s release last year.

  1. While we wait for finalization of the ET3 protocols, will billing be allowed retroactively?

If CMS follows other waiver provisions that they have been approving, then we would expect the waiver to be retroactive. However, that will be clearly identified when and if the final waiver is approved.

  1. Asbel spoke about Telehealth medical necessity, which we assume applies to the QHP.  Neither CMS nor the MAC has provided any guidance regarding MN guidance for the ambulance that is facilitating the telehealth.  CMS ET3 FAQ provides a non-answer. Can you advise?

You will need to understand the nuances around telehealth and what Medicare requires as a covered benefit for telehealth. Please see attached resources below

  1. Do we need to file an application for TIP?

That is unclear at this time. The AAA has been advocating for national policy that would not include an application process during this public health emergency. If CMS accepts our proposal, then we do not expect an application process.

  1. Will Medicare pay for signs and symptoms such as a cough that is not on our LCD list?

The Centers for Disease Control and Prevention (CDC) has established new codes related to COVID-19.  They are available in this link:  https://www.cdc.gov/nchs/data/icd/ICD-10-CM-Official-Coding-Gudance-Interim-Advice-coronavirus-feb-20-2020.pdf

  1. How can we bill for lift assists and basically public assist? For example, we are seeing increased med alarm pulls because in some of the senior assisted living or independent with aide service, the aide staff is not showing up or is late.  We are getting 911 calls for help getting dressed, move me from my chair to bed at night, etc. (We have one building with many PACE participants, so many Medicare primary)

Yes, you can bill for any response. I am assuming you are looking to understand who the payer source will be for those responses. Currently, Medicare does not pay for an ambulance response without a subsequent medically necessary transport to a covered destination.

The lift assist and public assist responses may be billed to whoever the caller source is if there is no state or local law that prohibits this practice.

Suggestion: You could work with your state legislature or local governing body to codify in statute or local ordinance the responsibility for these false alarms, or public assists are the responsibility of the requestor and invoke penalties if not paid. There are many local jurisdictions that codify this in law with prescribed penalties to try and deter this abuse.

  1. How does this impact the patients who typically are transported by sedan cars or gurney vans to dialysis, but now are confirmed COVID-19 or suspected and still need to be transported to Dialysis? Gurney Van or Sedan cars don’t have the isolation precautions to transfer those patients. Can those patients now be transported by BLS Non-Emergency ambulance?

Medicare has not changed its requirements for transporting beneficiaries to/from dialysis facilities.  We understand that some MACs recognize as a primary reason for ambulance transport patients who have a communicable disease or hazardous material exposure and must be isolated from the public or whose medical condition must be protected from public exposure.  Some MACs do not view this condition as a primary reason to transport a patient, however.  The AAA is seeking clarification from CMS to try to align MACs around the view that patients who require isolation because of a communicable disease or hazardous material exposure can be transported by ground ambulances.

  1. There is already an “I” origin/destination modifier for the site of transfer between modes of ambulances. Wouldn’t this new “I” confuse things?

Great question. Yes. We will wait and see final direction from CMS if they approved transport to a COVID-19 testing site.

  1. Does the use of the “I” modifier include a site such as a shelter that might be set up for COVID-19 patients? Specifically I am referring to a site that maybe the state or local authority has set up and is not directly tied to a hospital.

Yes, that is the waiver that we are seeking from CMS. They could recommend a different modifier. It should be noted that States do have the authority to request a waiver to allow for this, as well. You do not have to wait on the CMS.

  1. The ICD 10 codes related to COVID19 are not effective until April 1st. Once effective, can they be used on a run that occurred before that date?

On February 20, 2020, the Centers for Disease Control and Prevention issued guidance on the ICD-10 codes that should be used. You can find this guidance at the following site:

https://www.cdc.gov/nchs/data/icd/ICD-10-CM-Official-Coding-Gudance-Interim-Advice-coronavirus-feb-20-2020.pdf

  1. Is there anything on the end user if ambulance personnel need to document differently for billing purposes?

Best practices would be to provide instruction or edits within your PCR that identifies the following: (1) COVID-19 suspected or positive patient; (2) PPE equipment used (not just a general statement); and (3) any other pertinent information related to the inability to sign any forms due to local or state mandates.

Due to circumstances surrounding this national emergency that we have not experienced before, things are constantly changing. Documentation will be the CRITICAL in helping to obtain additional federal, state and local waivers. Accurate and reliable documentation will be key in building the case retrospectively.

  1. Have there been any signature requirement changes due to COVID 19?

CMS has provided the following guidance:

“At this time, suppliers should do their best to obtain proof of delivery and should notate the file that the beneficiary declined to sign.  Where FedEx or similar delivery services have altered their delivery protocols (such as leaving packages at the home without signatures) due to the COVID-19 pandemic, CMS will consider the revised protocols if conducting review absent suspicion of deliberate gaming or attempted fraud.  Suppliers should continue providing the necessary supplies and document the proof of delivery to the best of their ability (such as a picture of the delivery and/or notation in the file). “

  1. Do any of the waivers apply to the patient signature requirement? Are there links or support for how to learn about 1135? How do we know what our state has done regarding 1135 waiver? How do we work with our state to expand services via 1135 waiver?

The link below is a great tutorial on how 1135 waivers work and tracking existing waivers.

https://www.kff.org/medicaid/issue-brief/medicaid-emergency-authority-tracker-approved-state-actions-to-address-covid-19/

The health agency in your state would be your POC to engage regarding ambulance requests for expanded services via the 1135 waiver.

  1. Is there a specific documentation on the HCFA form’s for using the 1135 waiver?

Each payer is issuing specific claims guidance on how to bill for waived services through the 1135. You will need to check with your state Department of Insurance or Medicaid Agency. They should have resources online to assist you with identifying what specific documentation is needed.

  1. Has there been any discussion in the delay of Data Collection?

No.  At this point the program remains underway.  The first set of services required to submit were notified at the end of 2019.  CMS continues to develop the tool it will use to collect the data, which we expect to see later this summer or early fall.  However, if the pandemic continues, we will engage with CMS to determine how they view data collection.

If you have an additional questions, please email the AAA at info@ambulance.org

Presenters:

Asbel Montes
Senior Vice President of Strategic Initiatives and Innovation, Acadian Ambulance Service

Asbel has been a member of the American Ambulance Association (AAA) for eight years and has served on its Board of Directors; he currently is Chair of the Payment Reform Steering Committee. Asbel also sits on the board of the Louisiana Ambulance Alliance. He is a respected thought leader on reimbursement initiatives within the industry and is a requested speaker at many conferences. He has also been asked to testify as an expert witness before federal and state health committees regarding ambulance reimbursement.

Asbel began his employment with Acadian in May 2009. He oversees Acadian’s revenue cycle management, contract management, business office process improvements, and government relations for state and federal reimbursement policy initiatives.

In 1999, Asbel began working for an ambulance billing and consulting firm. After three years, he decided to work for a private, non‐emergency ambulance service. Since then, he has provided leadership in revenue cycle management to four ambulance agencies located throughout the Southeast.

Asbel pursued his education the non‐traditional way by attending college online while maintaining a fulltime job. He received an associate’s degree in accounting in 2007 and graduated in November 2010 with a bachelor’s degree in business management.

Asbel is married to Stephenie Haney‐Montes. He has one daughter and resides in Carencro, LA.

Kathy Lester, Esq.
Principal, Lester Health Law

Kathleen Lester provides legal and strategic advice on legislative and regulatory matters involving Medicare and Medicaid coverage and reimbursement, quality measurement (including valuebased purchasing programs), federal health care funding, health information technology, and medical and Internet privacy — including the Health Insurance Portability and Accountability Act (HIPAA) regulations, other federal and state privacy laws.

Ms. Lester practices at the intersection of health care law and public policy. She focuses her practice on finding solutions to her clients’ problems by assisting them with compliance programs and by seeking legislative or regulatory modifications. She has worked with health care providers and suppliers to modernize their payment structures within the Medicare program. She also assists non-profit organizations navigate the complex maze of federal funding and the authorization process for public health programs. She has worked with manufacturers to ensure coverage and appropriate reimbursement. She helps clients identify and resolve issues that arise from creating, collecting, maintaining, using, and disclosing personal health information. She has been deeply involved in measure development, as well as the creation and implementation of value-based purchasing programs in the Medicare program.

Ms. Lester has served a wide variety of health care providers, including physicians, dialysis facilities, hospitals, long-term care providers, home respiratory suppliers, pharmaceutical manufacturers, device companies, and patient organizations. She also has assisted with the formation and growth of industry-wide coalitions. Ms. Lester has experience in all three branches of the federal government.

Ms. Lester served as a privacy consultant in the Office of General Counsel to the U.S. Department of Health and Human Services (HHS), where she finalized the HIPAA Privacy Rule. Ms. Lester also served as law clerk to the Honorable Michael S. Kanne, Circuit Judge, U.S. Court of Appeals for the 7th Circuit and worked for Senator Richard G. Lugar (R-IN). Prior to opening her own firm, Ms. Lester was a partner in the health care group at Patton Boggs LLP.

During her time at Johns Hopkins, Ms. Lester served on a number of research and review boards, including the Human Genome Project’s Ethical, Legal, and Social Issues Working Group. She has an undergraduate degree in biology with an emphasis on microbiology and genetic research.

Ms. Lester received her J.D. from Georgetown University (cum laude), her M.P.H. from The Johns Hopkins School of Hygiene and Public Health, and her B.A. from DePauw University (magna cum laude). She is a member of the District of Columbia, Indiana, and Maryland bars and is admitted to the U.S. Court of Appeals for the 7th Circuit.

CMS Releases Update Guidance on Hospital EMTALA Obligations Related to COVID-19

On March 9, 2020, CMS published a memorandum to State Survey Agency Directors that provides updated guidance on the obligations of hospitals and critical access hospitals (CAHs) under the Emergency Medical Treatment and Labor Act (EMTALA).  This guidance was issued in response to numerous inquiries regarding the EMTALA obligations of these facilities as they struggle…

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CMS Grants State of Florida’s 1135 Waiver Request for Coronavirus Response

On March 16, 2020, CMS approved an 1135 Waiver request submitted by the State of Florida. The State had requested the flexibility to waive prior authorization requirements, streamline its Medicaid enrollment process, and allow care to be provided in alternative settings to the extent an existing health care facility needs to be evacuated. The key…

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Understanding Medicare, Medicaid, and SCHIP Coverage of Ambulance Services under a Declared National State of Emergency

On March 13, 2020, President Donald J. Trump announced a national state of emergency in response to the COVID-19 pandemic. Previously, HHS Secretary Alex Azar had declared a public health emergency under Section 319 of the Public Health Service Act in response to COVID-19. This has prompted many AAA members to ask what impact, if…

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AAA Releases 2020 Medicare Rate Calculator

AAA 2020 Medicare Rate Calculator Now Available! The American Ambulance Association is pleased to announce the release of its 2020 Medicare Rate Calculator tool. The AAA believes this is a valuable tool that can assist members in budgeting for the coming year. This calculator has been updated to account for recent changes in Medicare policies,…

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CMS Posts 2020 Public Use File

On December 2, 2019, CMS posted the 2020 Ambulance Fee Schedule Public Use Files. These files contain the amounts that will be allowed by Medicare in calendar year 2020 for the various levels of ambulance service and mileage. These allowables reflect a 0.9% inflation adjustment over the 2018 rates. The 2020 Ambulance Fee Schedule Public…

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2018 National and State-Specific Medicare Data

The American Ambulance Association is pleased to announce the publication of its 2018 Medicare Payment Data Report. This report is based on the “Early Edition” of the 2018 Part B National Summary Data File (previously known as the Bess Report). The report consists of an overview of total Medicare spending nationwide, and then a separate…

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CMS Open Door Forum & Member Q&A – November 7th

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, November 7 from 2:00-3:30 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call.

CMS Ambulance Open Door Forum

November 7 | 2:00 PM ET
Participant Dial-In Number:  1-888-455-1397
Conference ID #: 4676500

Questions?

Have more questions? The AAA is here to help! Following the ODF the AAA will be publishing a follow up blog post going over any updates and important announcements.

AAA Follow Up Q&A

November 7 | 4:00 PM ET
1-800-250-2600
Pin: 82802314#
Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.

CMS Announces 2020 Ambulance Inflation Factor

On October 4, 2019, CMS issued Transmittal 4407 (Change Request 11497), which announced the Medicare Ambulance Inflation Factor (AIF) for calendar year 2020. The AIF is calculated by measuring the increase in the consumer price index for all urban consumers (CPI-U) for the 12-month period ending with June of the previous year. Starting in calendar…

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