New SNF Consolidated Billing Edits: FAQs

On April 1, 2019, CMS implemented a new series of Common Working File (CWF) edits that it stated would better identify ground ambulance transports that were furnished in connection with an outpatient hospital service that would be bundled to the skilled nursing facility (SNF) under the SNF Consolidated Billing regime. Unfortunately, the implementation of these new edits has been anything but seamless. Over the past few weeks, I have received numerous phone calls, texts, and emails from AAA members reporting an increase in the number of Medicare claims being denied for SNF Consolidated Billing. This FAQ will try to explain why you may be seeing these denials.  I will also try to provide some practical solutions that can: (1) reduce the number of claims denied by the edits and (2) help you collect from the SNFs, when necessary. Please note that, at the present time, there is no perfect solution to this issue, i.e., there is nothing that you can do to completely eliminate these claim denials.  The solutions discussed herein are intended only to minimize the disruption to your operations caused by these denials.   I am new to Medicare ambulance billing. Can you explain what the SNF Consolidated Billing...

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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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Release: CMMI Announces Ambulance Innovative Payment Pilot Program

February 14, 2019 For Immediate Release Contact Maria Bianchi American Ambulance Association 202-802-9020 info@ambulance.org CMMI Announces Ambulance Innovative Payment Pilot Program Washington, DC – Today, the Centers for Medicare & Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) announced the launch of the Emergency Triage, Treat and Transport (ET3) Model.  During the next five years, this model will test paying ambulance providers and suppliers when they transport beneficiaries to locations other than an emergency department, if the alternative location is more appropriate medically for the patient.  It will also test paying for health care services provided by qualified health care professionals or through telehealth at the scene even if the ambulance does not transport the patient. While there are several important details yet to be released, this model appears to track the recommendations the American Ambulance Association, our members, and other industry partners have been working with CMS to implement. “Over the last 7 years, the AAA and our members have been working to develop an innovative payment framework to modernize the Medicare ambulance benefit,” said AAA President Aarron Reinert. “We are pleased that CMS is taking this important step and look forward to working closely with Administrator (more…)

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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Update on HHS OIG Reports on Ambulance Services

Update on HHS Office of the Inspector General Reports on Ambulance Services The HHS Office of the Inspector General (OIG) released an update to the Work Plan as the year comes to a close.  There are no new projects specific to ambulance services, but the update does provide a summary of three projects that have been completed or are in progress. Medicare Part B Payments for Ambulance Services Subject to Part A Skilled Nursing Facility Consolidated Billing Requirements (expected release 2019). In this work, the OIG  seeking to determine whether ambulance services paid by Medicare Part B were subject to Part A SNF consolidated billing requirements. The OIG will also assess the effectiveness of edits in CMS’s Common Working File to prevent and detect Part B overpayments for ambulance transportation subject to consolidated billing. Prior OIG reports have identified high error rates and significant overpayments for services subject to SNF consolidated billing. Ambulance Services – Supplier Compliance with Payment Requirements (partially completed; remainder expected release 2019). Prior OIG work has found that Medicare made inappropriate payments for advanced life support emergency transports. The OIG seeks to determine whether Medicare payments for ambulance services were made in accordance with Medicare requirements. ...

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Federal District Court Judge Strikes Down the ACA

On December 14, 2018, a federal district court judge for the Northern District of Texas issued a ruling striking down the Affordable Care Act (ACA) on the grounds that the Individual Mandate was unconstitutional, and that the rest of the law cannot withstand constitutional scrutiny without the Individual Mandate. District Court Judge Reed O’Connor’s decision relates to a lawsuit filed earlier this year by 20 states and two individuals. The plaintiffs argued that the Tax Cuts and Jobs Act of 2017 — which amended the Individual Mandate to eliminate the penalty on individuals that failed to purchase qualifying insurance effect January 1, 2019 — rendered the Individual Mandate unconstitutional. The plaintiffs further argued that the Individual Mandate was inseverable from the rest of the ACA, and, therefore, that the entire ACA should be struck down. The defendants in this case were the United States of America, the U.S. Department of Health and Human Services (HHS), Alex Azar, in his capacity as the Secretary of HHS, and David J. Kautter, in his capacity as the Acting Commissioner of the Internal Revenue Service (IRS). 16 states and the District of Columbia intervened as additional defendants. In order to properly understand the district (more…)

HHS Releases Communication Checklist to Aid First Responders

HHS Releases Checklist to Aid First Responders in Communicating Effectively with Patients The U.S. Department of Health and Human Services (HHS) Office of Civil Rights (OCR) has released a plain language checklist that is intended to aid First Responders during emergencies that involve individuals with Limited English Proficiency (LEP) and communications related disabilities. The AAA issued numerous articles to its members in 2016 about the newly published requirements for all healthcare providers, including EMS agencies, under the nondiscrimination provisions of the Affordable Care Act (ACA) Section 1557. The requirements are intended to prevent discrimination in the provision of healthcare and ensure that all individuals can meaningfully participate in their healthcare treatment, including those patients with LEP and other communications related disabilities. The announcement yesterday is intended to provide additional resources for healthcare providers to ensure compliance with the ACA Section 1557. The checklist includes numerous recommendations and action steps that EMS agencies can utilize to ensure that they are serving all members of a community in a meaningful way. These recommendations include conducting research about the communities by accessing U.S. Census Bureau data, engaging Centers for Independent Living and local assistance groups, and by preparing emergency messaging that can be...

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