To make your comments, go to THIS SITE. Click on “Submit a Comment”. Click the first drop-down menu and select “proposed rules” then enter this code in the “search by code or keyword”: CMS-2010-0209-0001. You will see the proposed rule come up on the search results. Look to the right and click on submit a comment.

Please also see the full text of what has been proposed in the American Recovery and Reinvestment Act of 2009 by clicking here.

We will be discussing field data, Medicare laws and regulations, and other EMS billing topics. Contact us today if you are interested in attending.

Internet-Based Medicare Enrollment Is NOW Available

Internet-Based Medicare Enrollment is now available for Medicare Physicians and Non-Physician Practitioners (All States and the District of Columbia).

It’s Fast, Secure, and Easy!

Now there’s a better way for physicians and non-physician practitioners to enroll or make a change in their Medicare enrollment information.  The Internet-based Provider Enrollment, Chain and Ownership System (PECOS) will allow physicians and non-physician practitioners to enroll, make a change in their Medicare enrollment, view their Medicare enrollment information on file with Medicare, or check on the status of a Medicare enrollment application via the Internet.

The Centers for Medicare & Medicaid Services (CMS) will make Internet-based PECOS to all organizational providers and suppliers (except durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) suppliers) later this year.

Fast
By submitting the initial Medicare enrollment application through Internet-based PECOS, a physician or non-physician practitioner’s enrollment application can be processed as much as 50 percent faster than by paper.  This means that it will take less time to enroll or make a change in an existing enrollment record.  For additional information about the types of changes that must be reported, go to the download section of www.cms.hhs.gov/MedicareProviderSupEnroll.

Secure
Internet-based PECOS meets all required Government security standards in terms of data entry, data transmission, and the electronic storage of Medicare enrollment information.  Only authorized individuals can enter enrollment information into PECOS or view PECOS data from the Internet.  Authorized individuals include physicians and non-physician practitioners.  Their User IDs and passwords protect the access to their enrollment information.  After physicians or non-physician practitioners create User IDs and passwords or change their passwords, they should keep this information secure and not share it with anyone.  By safeguarding their User IDs and passwords, they are taking an important step in protecting their enrollment information.  CMS does not disclose Medicare enrollment information to anyone except when we are authorized or required to do so by law.

Easy
Internet-based PECOS is a scenario-driven application process with front-end editing capabilities and built-in help screens.  The scenario-driven application process will ensure that physicians and non-physician practitioners complete and submit only the information necessary to enroll or make a change in their Medicare enrollment record. 

There are three basic steps to completing an enrollment action using Internet-based PECOS.  Physicians and non-physician practitioners must:

1. Have an NPPES User ID and password to use Internet-based PECOS.
   • For security reasons, physicians and non-physician practitioners should change passwords periodically, at least once a year.  For information on how to change a password, go to the NPPES Application Help page available at https://nppes.cms.hhs.gov/NPPES/Welcome.do and select the “Reset Password Page” under the NPPES Application help page.

2. Go to Internet-based PECOS at https://pecos.cms.hhs.gov and complete, review, and submit the electronic enrollment application via Internet-based PECOS.

3. Print, sign and date the Certification Statement (blue ink recommended) and mail the Certification Statement and all supporting paper documentation to the Medicare contractor. 

Note: A Medicare contractor will not process an Internet enrollment application without the signed and dated Certification Statement and the required supporting documentation.  In addition, the effective date of filing an enrollment application is the date the Medicare contractor receives the signed Certification Statement that is associated with the Internet submission. 

Additional Information

For information about Internet-Based PECOS, including important information that physicians and non-physician practitioners should know before submitting a Medicare enrollment application via Internet-based PECOS, go to www.cms.hhs.gov/MedicareProviderSupEnroll.

CALENDAR

The General Assembly was not in session this week.  Instead, the House and Senate Appropriations Committees met in joint hearings to hear from state agencies on their proposed budgets from the governor.

BUDGET & MEDICAID

On Friday, The Department of Community Health (DCH) and the Department of Human Resources (DHR) presented their FY 2009 Amended Budget and their FY 2010 Budget to a joint meeting of the House and Senate Appropriations Meetings.

DHR received many questions from legislators on the potential costs associated with the Division of Public Health being moved to DCH.  DHR was not able to provide any details and the governor’s office insists that any re-structuring will be revenue neutral.

The 1.6% taxes on health insurance providers and hospitals was the item that received the most discussion during DCH’s presentation.  DCH is still debating on how to assess such a tax on hospitals (whether it will be on total patient revenue, on the number of beds, or another method).

DCH also informed legislators that the governor’s office is still working on the legislation that is required to implement these new taxes.  One potential problem already developing is that some legislators are already discussing possible exemptions of certain hospitals from the new taxes.

Some of the most influential legislative leaders are insisting that they are not going to implement these new taxes and another source of revenue or cuts will be needed.  These same legislators also insist that raising the tax on tobacco related products is not an option.

The governor’s office has said that the governor would reconsider these new fees if a stimulus package from the federal government included funds for Medicaid.

NEW LEGISLATION

HB 19 – creating penalties for using a cell phone while driving

HB 23 – outlaws using a cell phone or text messaging if you are under 18

HB 105 – allows emergency 9-1-1 systems to direct non-emergency calls for public safety agencies.

HB 31 – repealing the law allowing red light cameras

SB 5 – requires seat belts in pickup trucks

This Special Edition article describes SNF Consolidated Billing (CB) as it applies to ambulance services for SNF residents.

Clarification:

The SNF CB requirement makes the SNF responsible for including on the Part A bill that it submits to its Medicare intermediary almost all of the services that a resident receives during the course of a Medicare-covered stay, except for a small number of services that are specifically excluded from this provision. These “excluded” services can be separately furnished to the resident and billed under Medicare Part B by a variety of outside sources. These sources can include other providers of service (such as hospitals), which would submit the bill for Part B services to their Medicare intermediary, as well as practitioners and suppliers who would generally submit their bills to a Medicare Part B carrier. (Bills for certain types of items or equipment would be submitted by the supplier to their Durable Medical Equipment Medicare Administrative Contractor (DME MAC).

When the SNF Prospective Payment System (PPS) was introduced in 1998, it changed not only the way SNFs are paid but also the way SNFs must work with suppliers, physicians, and other practitioners. CB assigns the SNF the Medicare billing responsibility for virtually all of the services that the SNF residents receive during the course of a covered Part A stay. Payment for this full range of service is included in the SNF PPS global per diem rate.

The only exceptions are those services that are specifically excluded from this provision, which remain separately billable to Medicare Part B by the entity that actually furnished the service. See MLN Matters Edition SE0431 for a detailed overview of SNF CB, including a section on services excluded from SNF CB. This instruction can be found at http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0431.pdf on the CMS website.

Ambulance services have not been identified as a type of service that is categorically excluded from the CB provisions. However, certain types of ambulance transportation have been identified as being separately billable in specific situations, i.e. based on the reason the ambulance service is needed. This policy is comparable to the one governing ambulance services furnished in the inpatient hospital setting, which has been subject to a similar comprehensive Medicare billing or “bundling” requirement since 1983. Since the law describes CB in terms of services that are furnished to a “resident” of a SNF, the initial ambulance trip that brings a beneficiary to a SNF is not subject to CB, as the beneficiary has not yet been admitted to the SNF as a resident at that point.

1. A trip for an inpatient admission to a Medicare-participating hospital or critical access hospital (CAH) (See discussion below regarding an ambulance trip made for the purpose of transferring a beneficiary from the discharging SNF to an inpatient admission at another SNF.);
2. A trip to the beneficiary’s home to receive services from a Medicare-participating home health agency under a plan of care;
3. A trip to a Medicare-participating hospital or CAH for the specific purpose of receiving emergency services or certain other intensive outpatient services that are not included in the SNF’s comprehensive care plan (see further explanation below); or
4. A formal discharge (or other departure) from the SNF that is not followed by readmission to that or another SNF by midnight of that same day.

1. Cardiac catheterization;
2. Computerized Axial Tomography Imaging (CT) scans;
3. Magnetic Resonance Imaging (MRI) services;
4. Ambulatory surgery involving the use of an operating room (the ambulatory surgical exclusion includes the insertion of percutaneous esophageal gastrostomy (PEG) tubes in a gastrointestinal or endoscopy suite);
5. Emergency room services;
6. Radiation therapy;
7. Angiography; and
8. Lymphatic and venous procedures.

Since a beneficiary’s departure from the SNF to receive one of these excluded types of outpatient hospital services is considered to end the beneficiary’s status as an SNF resident for CB purposes with respect to those services, any associated ambulance trips are, themselves, excluded from CB as well. Therefore, an ambulance trip from the SNF to the hospital for the receipt of such services should be billed separately under Part B by the outside supplier. Moreover, once the beneficiary’s SNF resident status has ended in this situation, it does not resume until the point at which the beneficiary actually arrives back at the SNF; accordingly, the return ambulance trip from the hospital to the SNF would also be excluded from CB.

Other Ambulance Trips

A beneficiary’s departure from an SNF is not considered to be a “final” departure for CB purposes if he or she is readmitted to that or another SNF by midnight of the same day (see 42 CFR 411.15(p)(3)(iv)). Thus, when a beneficiary travels directly from SNF 1 and is admitted to SNF 2 by midnight of the same day, that day is a covered Part A day for the beneficiary, to which CB applies. Accordingly, the ambulance trip that conveys the beneficiary would be bundled back to SNF 1 since, under §411.15(p)(3), the beneficiary would continue to be considered a resident of SNF 1 (for CB purposes) up until the actual point of admission to SNF 2.

However, when an individual leaves an SNF via ambulance and does not return to that or another SNF by midnight, the day is not a covered Part A day and, accordingly, CB would not apply.

Roundtrip to a Physician’s Office

If an SNF’s Part A resident requires transportation to a physician’s office and meets the general medical necessity requirement for transport by ambulance (i.e., using any other means of transport would be medically contraindicated) (see 42 CFR 409.27(c)), then the ambulance roundtrip is the responsibility of the SNF and is included in the PPS rate. The preamble to the July 30, 1999 final rule (64 Federal Register 41674-75) clarifies that the scope of the required service bundle furnished to Part A SNF residents under the PPS specifically encompasses coverage of transportation via ambulance under the conditions described above, rather than more general coverage of other forms of transportation.

Noncoverage of Transportation by Any Means Other Than Ambulance

Ambulance Corrections

The Centers for Medicare and Medicaid Services (CMS) allows providers to take advantage of the telephone reopening line to make simple corrections to processed Medicare claims.

In reviewing several of the ambulance appeals received, it is noted that there are a lot of corrections being sent in as appeals by ambulance providers that can be reviewed on the telephone reopening line. Specifically, allowing ambulance providers to call in only those corrections that require a GW modifier be added to the claim. These are not appeals, but simply corrections to claims that denied because the modifier was not used and the patient was in a Hospice environment.

Effective, Monday, February 9, 2009, if you have a claim that falls into this category and has been denied, you can call the toll-free Clerical Error Reopening lines to get the claim corrected. The Clerical Error Reopening lines are located at 

http://www.cahabagba.com/part_b/contact_phone.htm. This will save time and expedite payment avoiding needless paperwork and delays due to timeliness factors for appeals. Additional information on Clerical Error Reopenings is located on our Web site at http://www.cahabagba.com/part_b/claims/clerical_error_reopen.htm.

History was made January 7, 2009, as Paramedic Mike Alt of the NIOC Sugar Grove Fire and Emergency Services Department in Pendleton County submitted West Virginia’s first electronic patient care record.

The record was successfully submitted through WVPreMIS, West Virginia’s premiere Electronic Patient Care Record (EPCR) data submission and management system.

The Electronic Patient Care Record is designed to replace the current paper-based record that squads must submit after each response. The new electronic format will open the door to data and quality analysis, and will allow squads and the EMS system to focus on performance metrics with the goal to improve the quality of pre-hospital care in the State.

WVPreMIS, the de-facto standard EPCR system for West Virginia, was designed and developed by the EMS Performance Improvement Center (EMSPIC) of North Carolina.  The West Virginia Office of EMS began its partnership with EMSPIC in the winter of 2007, and has been working to implement West Virginia’s unique standards into the system. Access to WVPreMIS will be provided to squads free of charge in order to boost adoption in the State and provide a benchmark for EPCR system quality.

While a handful of small set-backs have been presented during the course of development, EMSPIC has worked diligently to deliver a production-ready product for first quarter 2009 deployment.

Squads planning their move to the electronic patient care record platform can either adopt WVPreMIS or implement one of West Virginia’s certified third-party EPCR solutions. Only certified systems  and WVPreMIS may submit electronic run data in West Virginia.

Squads are encouraged to talk with the West Virginia State Office of EMS, approved vendors, and the EMS Performance Improvement Center to determine the best solution to fit their needs.