CMS Open Door Forum
June 16, 2004
CMS held the bimonthly Open Door Forum on June 16, 2004 to discuss issues
related to Medicare that affect the EMS industry.
The Medicare Modernization Act (MMA) contains several
provisions for Ambulance reimbursement.
One of which is an additional percentage increase for rural
suppliers. CMS announced that the
percentage has been calculated but has not received final approval. When the final approval has been received,
CMS will reissue Change Request (CR) 3009 to provide detailed instructions to
contractors on how these changes will be implemented. The goal is to have the transmittal issued by
Friday, June 18, 2004.
Bill Rogers, CMS, stated that he had received approximately
12 emails from various suppliers regarding the increased concerns for
transporting bariatric patients. He
welcomed other providers to submit additional comments to brogers@cms.hhs.gov.
Another tabled topic from past meetings was related to the
transferal of HMO patients to network hospitals. CMS stated that they are working on this
issue and should have additional information at the next open door forum
meeting.
The call was opened for general discussion.
Jeff White, Johnston Ambulance Service, met with CMS at
the Baltimore office during the
call to discuss the issue related to Bariatric Transports. Jeff provided CMS with additional information
related to the issue and the increasing concerns on the provider's behalf. In order to transport these patients,
specialized vehicles, and specialty equipment is required. In addition, the ambulance company must send
several crews to lift the patient, which puts several ambulances out of service
for extended periods of time. The cost of
the specialized equipment and the number of personnel that is required to
perform the transport, as well as the liability and worker's comp
considerations, outweigh the current reimbursement for these types of
transports. A request was made for CMS
to consider a method of additional reimbursement for these types of calls.
CMS stated that they were currently reviewing the
information that they have received as well as the current ambulance
regulations to determine if additional payment can be allowed. One caller responded that HMO plans in their
region would allow the transporting agency to bill for the multiple crews that
were sent to transport the patient; however, this arrangement had to be
negotiated prior to the service being rendered.
Several comments were made from various callers regarding the
current Physician Certification Statements (PCS). CMS stated that a request was made to
eliminate the need for the PCS. The
Department of Justice and FBI would not agree to "sign off" on this policy
change, based on open investigations that are being conducted. A caller stated that CMS must either decide
to eliminate the need for the PCS form or enforce the physicians to be
responsible for filling out these forms accurately. "At this time, the forms are a joke. The physicians either will refuse to fill out
the form or will fill it out inaccurately."
CMS advised providers to review the specific guidelines which will allow
individuals that are involved in the patient's care to fill out the forms, as
well as a provision, if after 21 days, no PCS is received, the
claim can be filed to Medicare. They
advised providers to work with the local carriers to educate physicians and
facilities related to these requirements.
CMS stated that they would continue to work internally to attempt to
repeal the requirements; however, they seemed to be "deadlocked" at this time.
A question was asked related to the percentage of increase
based on the MMA that will be effective in July. A percentage increase of 1% urban, 2% rural
will be effective for dates of service July
1, 2004. This percentage
increase will be applied to the Medicare Fee Schedule portion of the blended
rate. An additional percentage will be
applied to rural providers that are ranked in the lowest percentile population
areas. This percentage has not been
finalized but will be released later this week.
A question was asked of CMS related to the designation of
emergency vs. non-emergency. CMS
responded that if a call is dispatched as non-emergency, the transport can not
be "upgraded" to emergency even if the patient's condition warranted an
emergency situation. The determination
of emergency is made based on how the ambulance was dispatched and if they
responded immediately to the call. Note:
Emergency vs. Non-Emergency is based on how the call is dispatched. The level of service (ALS vs.BLS)
is determined by services rendered to the patient.
The call ended at 3:00 with additional questions in
queue. The next call is scheduled for
August 18 at 2:00 pm.