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Tag: ALS Assessment

Summary of September 2017 Ambulance Open Door Forum

Written by David Werfel on . Posted in Medicare, Member-Only, News, Reimbursement.

On September 14, 2017, CMS held its latest Open Door Forum. As usual, it started with a few announcements, as follows:

  1. “Locality” Rule – On 6/16/17 CMS issued Transmittal 236, to amend the Benefit Policy Manual, Chapter 10, section 10.3.5 to give Medicare Administrative Contractors discretion to determine the “locality”. This is for the issue of the nearest appropriate facility.

Transmittal 236

  1. ALS Assessment – The same Transmittal also amended section 30.1.1 to indicate that if an ALS assessment is performed, then the ALS emergency base rate shall be paid, even if there is no ALS intervention.
  2. Multiple Patient Transports – On 9/1/17, CMS issued Transmittal 3855 to restore to its Claims Processing Manual, Chapter 15, section 30.1.2 instructions for multiple patients transported in the same vehicle. This is not a change in policy. The section was inadvertently omitted from the Internet Only Manual.

Transmittal 3855

  1. Temporary Adjustments – The 2%, 3% and 22.6% temporary adjustments for ground ambulance transports originating in urban, rural and super-rural areas will expire 12/31/17, unless legislation is enacted. Later on the call, they indicated that they are aware of a legislative initiative in Congress that includes this issue (S.967, H.R. 3236).

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       Following these announcements, a Q & A period ensued. Most of the questions were not answered on the call, other than to advise the caller to submit their question via e-mail and CMS will respond to their concern via e-mail or to contact their Medicare Administrative Contractor.

Two items of note in the Q & A were as follows:

  • CMS has left it up to the MACs to define the “locality” for purposes of the nearest appropriate facility requirement. Therefore, providers and suppliers should ask their MAC for their definition.
  • CMS was asked whether the prior authorization program would continue nationwide, after this year. The representatives from CMS did not answer the question other than to advise the person who asked the question to submit it in writing to CMS.

Have questions? Please write to the Werfels at bwerfel@aol.com.

Medicare “Locality” Rule & ALS Assessment

Written by David Werfel on . Posted in Government Affairs, Member-Only.

“Locality” Rule – MAC Discretion – Since the inception of the CMS Internet Only Manual (in 2003), the Benefit Policy Manual 100-02, Chapter 10, section 10.3.5 has always defined “Locality” as:

The term “Locality” with respect to ambulance service means the service area surrounding the institution to which individuals normally travel or are expected to travel to receive hospital or skilled nursing services.

An example is then listed to indicate that the ambulance transportation to either of two large metropolitan hospitals that regularly provide services to the small community where the emergency arose would be covered destinations.

On June 16, 2017, CMS issued Transmittal 236 to add the following at the end of the paragraph before the example:

The MAC’s have the discretion to define locality in their service areas.

Effectively, there is no change as Carriers and Intermediaries (now MACs) have always had discretion to determine the “locality” around each facility. Often, they did this with mileage edits, e.g. in an urban area, they may have set a parameter of 15 miles, but in a rural area, they have allowed a much larger area. Nevertheless, it is a good time to ask your MAC for their definitions of the localities in their service area or the mileage edits that they use.

A copy of the Transmittal can be obtained at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R236BP.pdf

ALS Assessment

The same Transmittal made two changes to the CMS definition of “ALS Assessment”, as listed in the Benefit Policy Manual, 100-02, Chapter 10, section 30.1.1, as follows:

1. Assuming the ALS assessment is performed and meets the definition, this section now states that the services provided by the supplier or provider “shall” be covered at the ALS emergency level. Previously, the definition indicated the services “may” be covered at the ALS emergency level. This change was needed as some MACs thought they did not have to pay ALS emergency when the ALS assessment is performed in accordance with the definition.

2. The other change was to add to the end of the paragraph “and all other coverage requirements are met”. In other words, aside from providing the ALS assessment in accordance with the definition, there must also be ambulance transportation, the origin/destination requirements are met, the provider/supplier must meet all vehicle and crew requirements, transportation was medically necessary, the ALS assessment was medically necessary, etc.

The effective date for the changes noted above is September 18, 2017.

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