December 9, 2009

AAA MEMBER ADVISORY

TO:           AAA Membership

FROM:     Brian Werfel

                AAA Medicare Consultant

RE:           Summary of December 9 Ambulance Open Door Forum

On December 9, 2009, CMS held its latest Open Door Forum for ambulance.   CMS started with the following announcements:

• Medicare Contractor Provider Satisfaction Survey – CMS announced that the 2010 survey will begin shortly.   CMS expects to mail surveys to approximately 30,000 Medicare providers chosen by random, including ambulance providers and suppliers.   The survey measures overall provider satisfaction with Medicare contractors.
• SNF Consolidated Billing – CMS provided further clarification on whether roundtrip transports from an SNF to an Emergency Department and back should be bundled to the SNF or billed separately to Medicare Part B during the first 100 days of an SNF stay.   Per CMS, these transports should be billed to Medicare Part B, as they are excluded from SNF Consolidated Billing.   Note: this is not a change in policy, just a clarification based on questions CMS has previously received.   A MedLearns Matters Article on SNF Consolidated Billing (SE0433) can be downloaded from the Ambulance Open Door Forum homepage at: http://www.cms.hhs.gov/OpenDoorForums/10_ODF_Ambulance.asp.
• 2010 Ambulance Fee Schedule – CMS announced that the 2010 Public Use File containing the rates for CY 2010 will be available for download no later than Friday, December 18, 2009.   Once it becomes available, the Public Use File can be downloaded from the Ambulance Home Page at: http://www.cms.hhs.gov/AmbulanceFeeSchedule/02_afspuf.asp .
• 2010 Ambulance Inflation Factor – CMS confirmed that the inflation update for 2010 will be 0.0%.   This was previously announced in Transmittal 1861, issued November 27, 2009.

Following these announcements, there was a Q&A period.   Most of the 18 callers were asked to submit their questions to CMS via email or by calling a CMS Regional Office, and these questions will be answered privately.   The following questions were answered on the call:

• CMS confirmed that wheelchair van and stretcher van transports to a physician's office are non-covered services.   Accordingly, they generally would not be bundled to the SNF during the Part A Period, and should be billed to the patient.
• The NPI of the referring physician is not required for ambulance transports.
• Transports to a free-standing MRI center are not excluded from SNF Consolidated Billing, and, therefore, are the responsibility of the SNF.   However, if the MRI services were received at a hospital, then the transports would be excluded.   Note: transports to and from dialysis are excluded regardless of whether the dialysis center is hospital-based or free-standing.
• A roundtrip transport from a rehabilitation hospital to the ED and back on the same calendar day is considered to be an "interrupted stay", and should be billed to the rehabilitation hospital.

There were 242 people on the call.   The next Ambulance Open Door Forum will be on Wednesday, February 3, 2010.