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Details of the Medicare fee schedule final rule PAGE, WOLFBERG & WIRTH LLC MECHANICSBURG, Pennsylvania — Page, Wolfberg & Wirth, LLC has obtained from Washington an advance copy of the FINAL RULE for the Medicare Fee Schedule that is scheduled to be published in the Federal Register on February 27th. Here are the long-awaited final numbers and a brief summary of the major provisions of the final rule, scheduled for implementation on April 1, 2002. THE NUMBERS: The new conversion factor (base rate) for ambulance services is $170.54. The unadjusted base rate (UBR) numbers are as follows:
LOADED MILEAGE: $5.47 As in the Proposed Rule, the unadjusted base rates are adjusted based on your Geographic Practice Cost Index (GPCI) figures for your particular area, so your actual base rate may vary somewhat from these figures. Other significant new developments in the Fee Schedule Final Rule: PHASE IN PERIOD EXTENDED TO 5 YEARS: There is now a FIVE YEAR phase-in period instead of a four-year phase in period as originally proposed. During the phase-in period, your payments will be determined by blending a portion of your existing payment rate with a portion of the fee schedule payment rate. The phase-in schedule is as follows: YEAR -- EXISTING PAYMENT % -- FEE SCHEDULE PAYMENT % 2002--80%--20% MANDATORY ASSIGNMENT: Assignment is mandatory under the new fee schedule. That means that you must accept the Medicare amount as payment in rull and may only bill the patient for unmet copayment and deductible amounts, NOT your full charges. MEDICAL NECESSITY: for payment to be made, the patient's condition must meet medical necessity requirements for ambulance transport at the level of service billed (no more mandatory-ALS payments). For non-emergency transports, the patient must be EITHER (1) bed confined (under the current definition); OR (2) have a medical condition, "regardless of bed confinement," such that "transportation by ambulance is medically required." Therefore, bed confinement is not the SOLE determinant of medical necessity for non-emergency transports. PHYSICIAN CERTIFICATION STATEMENTS: Medicare has changed the rules for physician certification statements (PCS). Effective April 1, ambulance services must have a PCS form signed by the attending physician BEFORE rendering a nonemergency transport for a REPETITIVE PATIENT. For NON-REPETITIVE PATIENTS, and for UNSCHEDULED TRANSPORTS, the ambulance service must obtain a PCS FROM THE ATTENDING PHYSICIAN within 48 hours after the transport. If the ambulance service cannot obtain a PCS from the attending physician, only then may the ambulance service obtain a PCS from physician assistant, nurse practitioner, clinical nurse specialist, registered nurse or discharge planner employed by the facility and with knowledge of the patient's condition. If the ambulance service cannot obtain the PCS within 21 days after the transport, it may submit the claim if it has documented its attempt to obtain the PCS. The documentation must be a signed return receipt from the U.S. postal service OR similar service that evidences that the ambulance service made the attempt. Fax attempts are not specifically mentioned in the text of the final regulation. The presence of a PCS form does not conclusively mean that medical necessity is met. BASIC LIFE SUPPORT DEFINITION: There was some confusion in the Proposed Rule about including IV therapy in the basic life support payment. The Final Rule makes it clear that IVs are included in the BLS base rate ONLY in those areas where EMTs may start IVs under state or local law. ALS1 DEFINITION: An ALS1 level of service is defined as including an ALS assessment OR the provision of at least one ALS intervention. ALS2 DEFINITION: An ALS2 level of service has been clarified to mean the administration of at least THREE different medications AND the provision of at least one of the following procedures: manual defib/cardioversion; endotracheal intubation; central venous line; cardiac pacing; chest decompression; surgical airway; intraosseous line. Dextrose, normal saline and Ringer's lactate are NOT medications for purposes of the "three medication" rule. EMERGENCY DEFINITION: The new definition of an "emergency response," which qualifies for higher payment at the BLS and ALS1 levels, is "responding immediately . . . to a 911 call or the equivalent in areas without a 911 call system. An immediate response is one in which the ambulance supplier begins as quickly as possible to take the steps necessary to respond to the call." We are certain that there will be more issues that will arise once a more comprehensive review of all of the fee schedule documents is completed. Nevertheless, these are the highlights. In addition, this information is taken from our advance copy of the Final Rule itself (not including the many pages of Medicare's comments and the preamble to the actual Rule), and is subject to change depending upon the official publication of the Final Rule in the Federal Register. Check our website, www.pwwemslaw.com, for a complete copy of the Final Rule, which will be posted on February 27th on our web site's "Medicare Fee Schedule Resource Page." Page, Wolfberg & Wirth, LLC www.pwwemslaw.com A National EMS, Ambulance and Medical Transportation Law Firm 5010 E. Trindle Road, Suite 202 Mechanicsburg, PA 17050 (717) 691-0100 (717) 691-1226 (fax) © Copyright, 2002, Page, Wolfberg & Wirth, LLC. Anyone who receives this message is more than welcome and is encouraged to forward it on to others for their free use, as long as the message is kept in its original form and includes this disclaimer. Any other type of use or reproduction requires our prior consent. Please keep in mind that receipt of this message does not form an attorney-client relationship, and that neither this message nor the information contained on our web site is legal advice.
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