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www.SystemsDesignEMS.com


August 2014
 

 

NEWSLETTER

Annual Billing Workshop: September 10th 2014
Systems Design is proud to present our second Annual EMS Transport Billing Workshop/Conference on Wednesday, September 10th 2014. The workshop is free of charge, and lunch will be provided.

The venue for this event will be the Pickering Barn located in Issaquah, WA. Our featured presenter will be Maggie Adams from EMS Financial. Between 0900 and 1600, the workshop's agenda will cover as many important transport billing issues as possible, including:
 
Morning Session
Appeals & Research Department: Denied Claims & Medical Necessity (Megan Owen)
Emergency Documentation: Review & Update (Maggie Adams)
Industry Trends & Information regarding CMS and Medicaid (Maggie Adams)
Revenue Statistics & Analytics (Mark Spice)

Afternoon Session
HIPAA Review & Updates (Jody O'Brien)
Non-Emergency Documentation Updates (Maggie Adams)

Details about the workshop and pre-registration will be sent to everyone soon. Don't miss it!

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Pre-Authorizations on the Increase
If your agency transports patients in non-emergency situations, it is very likely that you will be required to have pre-authorization forms.  Medicare's required form for non-emergency transports is the Physician Certification Statement.  Many agencies are very familiar with the PCS as it has been around for a while.  However, other payers have their own forms for non-emergency transports, and knowing which form to use can mean the difference between a paid claim and a denied one.

Washington State Medicaid recently instituted pre-authorizations for non-emergency transports.  There is a form for these transports that needs to be completed and faxed before the transport.  The Medicaid HMOs that also need pre-authorization forms for non-emergencies are Molina, Amerigroup, and United HealthCare Community.

Here are the types of transports that are considered non-emergency: 
*    from one hospital to another hospital 
*    from a hospital to skilled nursing, adult family home, or assisted living 
*    from a hospital to patient's home 
*    round trips to and from dialysis or radiation 
*    round trips to and from medical appointments

In all cases, the transport must be medically necessary for payment and the documentation should explain why the patient could not go by wheelchair van or any other means.  The pre-authorization form does not take the place of your patient care report.

Each state has a unique mix of payers with different non-emergency requirements.  If you have any questions regarding pre-authorizations for your agency, please call our administrative line at 800-585-5242.  We can look at the payers in your region and identify which transports will need pre-authorizations.

 

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Legally Speaking:  Ambulance Bonus Payments 
It has only been a short 4 months since Congress approved the fee schedule for 2014 and they are already working on parts of the fee schedule for 2015.  On July 11, a proposed rule was issued to specifically address the rural and urban bonuses.

The bonus payments for urban, rural, and super-rural transports were originally scheduled to last only 18 months but have been extended annually since 2009.  Under the current rule, bonuses will expire on March 31, 2015.  The proposed rule will extend them again until March 31, 2016, which is good news for ambulance providers.

Along with extending the bonuses, the proposed rule changes the rural/urban designation of a small number of zip codes.  The point-of-pickup zip code is the key piece of information that determines which bonus level will be applied to your Medicare payment.  Census data from 2010 was used to re-classify the zip codes.

Nationally, only 222 zip codes will change.  122 zip codes will change from rural to urban, and payments will be reduced by 1%.  100 zip codes will change from urban to rural and receive a 1% increase in payments.   No super-rural zip codes will change.

Here are the changes for the Pacific Northwest: 
*    Alaska and Idaho have no changes to their zip codes 
*    Oregon has 6 zip codes that will change from rural to urban-97348, 97358, 97360, 97377, 97389, and 97446 
*    Washington has 2 zip codes that will change from rural to urban--99323 and 99348.

This is a proposed rule and no vote will be taken until after the comment period ends on Sept 2nd.  Additionally, Congress must consider the ambulance inflation factor before the 2015 ambulance fee schedule is finalized.

 

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Medicaid Revalidation
Many of you are familiar with the revalidation process providers are required to go through with Medicare. Washington Medicaid (Apple Health) recently began a state-wide revalidation process.   As with Medicare, Systems Design will send you the necessary signature forms, gather the required documents, and submit the revalidation packet to Medicaid.

If you are a provider with Washington Apple Health, a notice will be mailed to your office when it is time to revalidate.  The letter is usually easy to spot as it comes in a green-colored envelope and has the words "Time Sensitive" in big print.  Please forward the letter to our office and we will start the process right away.  Apple Health is only allowing 30 days to complete the packet.

One of the unique documents that Apple Health requires is proof of liability insurance.   If you do not have easy access to that document, you may wish to immediately determine where it is stored at your district.

For more information on the purpose and requirements of this process, please refer to the links below or contact Shelley Brewington at 800-585-5242.

Revalidations: 42 CFR 455, Subpart E and 42 CFR 455.414 

 

Federal Rules: 12/23/2011 CMCS Informational Bulletin  

 

State Requirements: WAC 182-502-0016 (1)(m) 

HIPAA Update

HIPAA Corner
What does a healthy HIPAA program look like and how does Systems Design fit into the HIPAA program at your organization?  Many providers are asking this question, especially in light of possible audits by the Office of Civil Rights.  This month, we will cover a snapshot view of 3 key HIPAA program elements-the compliance officer, the Notice of Privacy Practices (NPP) and Business Associate Agreements (BAA), with more to follow in the coming months.

Compliance Officer:  There are 2 main areas under HIPAA-privacy and security.  Privacy deals with knowing when you can and when you cannot share health information.  Security deals with the I.T. side-hardware, firewalls, servers, and data transmission.  HIPAA requires that you have both a privacy officer and a security officer.  If it works for your agency, one person can fill both roles.

We are often asked if Systems Design has a HIPAA officer and a HIPAA program. Also, if we are billing your transports, is that not enough to satisfy the requirements for your agency?  Every agency needs to manage their data and develop policies that fit their organization, so no-we cannot act as your HIPAA officer. We can, however, share information, resources, training, and experience.  We continually develop and update our own HIPAA program. We also enjoy sharing lessons learned.

There are numerous HIPAA resources available, some free and some not.  If your agency has an attorney, you may have received guidance materials.  Your liability insurance may also have sent HIPAA program materials.  Page, Wolfberg and Wirth have HIPAA Compliance materials that can be purchased.  Another good resource is the website for the Office of Civil Rights at http://www.hhs.gov/ocr/office/index.html. The OCR is the federal agency that oversees HIPAA law, and everything on their website is free.

Among the many things you can find on this website are sample forms, such as the Notice of Privacy Practices and Business Associate Agreements.   These two forms have important new language requirements under HIPAA.  As you will see in the next article, we are in the process of sending out new Business Associate Agreements for those who need it.  If you have not updated these forms recently, we can review your current forms and assist with the appropriate updates.  For a review, please call the administration line at 800-585-5242 and ask for Compliance.

CMS flagUpdated Business Associate Agreements 

In 2013, HIPAA was updated by the HITECH Omnibus Final Rule. In addition to a number of other changes, the Omnibus Final Rule requires that all Covered Entities (CEs) have Business Associate Agreements ("B.A.A.s") with their business associates by September 23, 2014.

Systems Design updated our standard B.A.A. in September 2013. We will send new B.A.A.s to our clients that have not completed updated agreements with us. These documents will be sent during the last week of August. If your organization completed a B.A.A. with Systems Design in the last 12 months, a new agreement will not be needed.

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The Appeals & Research Department
Systems Design is growing by one department!  Due to an increasing volume of challenging insurance denials for medical necessity, we are happy to introduce the Appeals & Research Department.  Megan Owen will manage this department, using her experience at Systems Design to tackle these denials head-on to get them paid.  

2013 and 2014 have brought a significant increase in insurance denials, typically for non-emergent and scheduled transports.  Medicare, in particular, has been more selective in paying non-emergent and scheduled transports, which has resulted in more denials. The Appeals & Research Department looks at each denied claim individually, and assesses if it can be appealed.  If a claim can be appealed, the Appeals & Research Department files all required documents with the insurance company, then follows the claim closely until further resolution is reached.

Although the Appeals & Research Department is fairly new, the knowledge we have gained is immeasurable, and we are learning more daily.  We are identifying the causes of claim denials and the factors that help appeals get paid.  We have also discovered the two keys to getting claims paid upfront: good documentation in trip reports and the inclusion of relevant forms that accompany these reports (ABNs, PCRs, pre-authorization forms, etc.).  This also holds true for writing a successful appeal.  A full description of the patient's condition at the time of transport is a helpful tool for supporting our appeals.   We look forward to sharing more tips and advice with our clients and Systems Design staff in the future to keep your billing as successful as possible!

If you have questions about the Appeals & Research Department or about appeals in general, please contact Megan Owen by phone, 360-394-7018, or email, megano@sdwems.com.

We welcome suggestions of topics of interest for future newsletters. Please contact our Executive Adminstration Assistant, Elen Sia, at 360.394.7028 or send her an email at ElenS@SDWems.com.

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Toll Free:  800.585.5242

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