Centers for Medicare and Medicaid Services (CMS) held a town hall meeting on February 4, 2004 to solicit feedback from the ambulance community regarding the implementation of the condition codes.  The town hall meeting was attended by over 100 representatives from the American Ambulance Association (AAA), International Association of Fire Chiefs, American College of Emergency Physicians, National Association of EMS Physicians, various ambulance services, and billing and consulting firms.

Dr. Richard Lawlor, Office of the Administrator, CMS provided opening remarks regarding the recent improvements to CMS including the Ambulance Open Door Forums and Town Hall Meetings in an effort to obtain supplier feedback prior to policy implementation.

Anne Tayloe, Health Insurance Specialist, CMS, Project Lead for Condition Code Project, stated that while the condition codes would provide consistent guidance for reporting medical necessity information, they would not provide payment guarantee.  The implementation of the codes would be voluntary for both ambulance suppliers and CMS contractor implementation.   She further stated that additional documentation may be required to support medical necessity.

Deb Gualt, Chair, AAA Federal Reimbursement Committee, as well as speakers from the floor expressed comments that the condition codes are necessary to ensure a standard decision making process on behalf of the contractors in determining payment for ambulance services.  A wide range of inconsistencies exist, not only between contractors but also within the contractors themselves.

The overwhelming response from those that made comments was to implement the condition codes quickly and consistently.  The current draft documents state that the condition code implementation would be voluntary for CMS contractors.  The consistent message to CMS was to mandate implementation of the condition codes to all CMS Contractors.  Kim Stanley, EMS Management & Consultants, commented as a former employee of a contractor, implementation must be mandatory in order for the condition codes to be implemented in a timely fashion.  With all of the current regulations that contractors are required to perform, a voluntary implementation would not result in the consistent payment arrangements that these condition codes are meant to provide.

Many comments were made regarding the current crosswalk to ICD-9 codes.  Many problems exist using this methodology such as the same ICD-9 was linked to multiple condition codes with different service levels.  An example given was abdominal pain - condition code 1 & 2 - both link to ICD-9 code 789.0, with both ALS and BLS service levels.  Another problem noted with ICD-9 codes is that they relate to very specific diagnostic coding.   Current contractor systems require these codes to be carried to the highest level of specificity, which could cause inappropriate denials for ambulance suppliers.  There were a few condition codes that do not currently crosswalk to an ICD-9 in which CMS stated that they would take the necessary steps to have new codes created. 

The ambulance supplier community stated their approval of the condition codes and the effort that has gone into the project this far.  CMS stated that their goal was to move forward quickly to implement this project as soon as possible.  The next step for CMS is to review all of the feedback received and discuss further with the contractors to determine how quickly these codes could be implemented.