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News & Developments

Red Flags Rules

After several delays, the Red Flags Rule was implemented on December 31, 2010. The Red Flags Rule is a set of regulations developed by the FTC requiring "creditors" to implement written identity theft prevention and detection programs into their day-to-day operations.

HIPAA Bottom Line

There's one message Dena Boggan, CPC, CMC, CCP, a privacy and security officer in Mississippi, wants to get across during her HIPAA training: "I tell my employees if they don't remember anything else about HIPAA, remember this - only access that information which you need to do your job. Period. I tell them if they follow that one simple rule, they'll do just fine."

Documentation & Reimbursement

Documentation has many important uses besides reimbursement. It is the legal record for your agency and for your patients, is shared with hospitals to provide continuity of care and is used for internal data collection and quality assurance. Over the next few months, our newsletter will feature a series of articles on documentation from the billing perspective.

Part 1: Dispatch

Let's start with the "How" of dispatch. To be considered an emergency transport, Medicare has 2 requirements: 1) the dispatch must be through a 911 or equivalent system and 2) the response must be immediate. This means the PCR needs to describe HOW you were dispatched and HOW you responded, even if 100% of your calls come through 911.

Part 2: Medical Necessity

Medicare patients make up a substantial portion of ambulance transports so it is important to understand their documentation requirements. One of the big requirements to receive payment from Medicare is that transports must be "medically necessary". How Medicare defines medical necessity is narrower than most of us would think. The fact that someone called 911 does not make a transport medically necessary and does not guarantee payment.

Medicare File Hygiene

For any medical services provider, the ability to bill Medicare is one of the foremost financial considerations in funding operations. Many of our clients ultimately bill anywhere from 40-70% of their transports to a Medicare plan. After the original enrollment is completed, the Medicare application process often becomes a distant, slightly painful memory, and maintaining correct information in your provider file is low on the priority list as long as the payments keep coming in. However, in this era of increasing scrutiny for fraudulent billing, including site visits to provider’s address of record by Medicare contractors, we are recommending that our clients develop a process to review the information contained in their Medicare provider file to ensure that any changes get properly reported to Medicare. The expectation by Medicare is contained in the quote below, which is taken directly off of a recent award letter to a new provider.

EFT Payment Logistics

Part of the Debt Collection Improvement Act of 1996 mandated that all Federal payers make their payments via EFT (electronic funds transfer) to save the costs of printing and mailing checks. Fortunately, this was not put into place immediately, but has been phasing in over the last 15 years, as Medicare has required all new providers and those making updates to their files to enroll to receive EFTs. There are very few providers who are still receiving paper checks from Medicare. EFTs have also been available with other Federal payers, like the VA, Railroad Medicare or Federal Corrections Facilities, but have been optional up to this point. We have received word from the VA that 2011 is the last year that EFT enrollment will be optional with them, and they will be pushing to get any stragglers enrolled before the end of the year. One reason that we have not aggressively pushed our clients in this direction is the large number of clients who share their County’s bank account with other medical providers, which causes a fair amount of consternation with the County Treasurer when an unidentified EFT arrives.

EMT Signatures

When you look at all the elements that go into documenting your PCR, requiring the crewmember’s signature seems very straight-forward. As our jobs become more paperless, the definition of a signature also changes. With the enormous emphasis on health care fraud, signatures have become an area of increasing scrutiny by Medicare and Medicaid—and not just for ambulance providers, but for physicians and hospitals, too.

Correcting PCR Documentation

The PCR is your legal record and your agency probably has a policy on how to amend, correct and clarify the PCR when information is not complete. From the billing perspective, we can make minor changes to the patient demographic information, such as a misspelled name or incorrect address. We do not make any changes to documentation that is related to patient care.

Occasionally, we will notice that the transport date on the PCR is incorrect. This is an item that we cannot legally change. In these cases, we will ask for clarification and an amended report so information is readily available if the insurance company requests a copy of the PCR.