CMS Opens Wider Window with Templates

Open Door = Open Window

Just a few weeks ago, the Centers for Medicare and Medicaid Services (CMS) opened a wider window for those of us in the ambulance industry to take a look at the future direction for supporting documentation expectations.

CMS-Opens-Wider-Window-with-Templates-08-16-2018

Part of the Patients Over Paperwork Project, CMS’s Provider Compliance Group (PCG) conducted an Open Door Forum nationwide conference call to review information requests. As part of this exercise CMS released a voluntary/options Non-Emergency Ambulance Transportation (NEAT) progress note template (view template here) for use by clinicians.

This marks the first time such a template has been released and most likely is a peek into the future, especially what can be expected to be the standard for qualifying reimbursement in the form of supporting documentation

Content Not New

The content and expectations are not new. While the template may pull all of CMS’s expectations together into one nice, neat, recommended flowing document, the burden of proof for medical necessity and reasonableness rest in the rules and regulations that have been and are currently in play.

CMS explains in the preamble to the template document that the template was “designed to assist a clinician in documenting the patient’s medical condition supporting coverage of repetitive, schedule Non-Emergency Ambulance Transportation (NEAT) under Medicare Part B.”

CMS continues on by reiterating what we all should know by now that the medical documentation for NEAT must prove the following…

  • The patient is “bed-confined”; and
  • The patient’s condition is such that other methods of transportation are contraindicated; or
  • If his or her medical condition regardless of bed confinement, is such that transportation by ambulance is medical required.

The section then continues by including the bed-confined criteria as outlined for many years by CMS.

Guidance

The really good part of this template is directed to the clinician and not directly to EMS field providers, at least at this time. Frankly, we in the ambulance industry should know this stuff like the back of our hand anyway.

But, as we all know, our friends in the clinician world often see things in our world from a completely different viewpoint. If we had a dollar for every time a clinician looked at us like we had a unicorn’s horn protruding from our foreheads, when requesting the need for additional medical necessity information; we certainly would not be penning this blog today.

This template provides a complete and logical combination of words and “check boxes” on a piece of paper for the clinician to follow when assisting us in making the case for a patient’s medical necessity and the reasonableness of the NEAT.

And…we can tell the clinician that the document was issued by CMS!

Voluntary but…

While the progress note template is voluntary, it’s best that we all review the document and pay attention to the contact and even to some extent the flow.

Plus it’s important that we ask the clinicians we interact with to consider using the document to help us make our case for billing purposes.

Regardless of whether or not the use of this document is forced upon all of us it provides us with a very valuable window on what CMS expects to find in written, supporting documentation to back-up a claim submitted for reimbursement.

By extension, it seems reasonable to assume that this information and level of detail will become, if it isn’t already, the standard for audit review expectations.

It will be interesting to see how the future plays out with regards to this new initiative.

Will the electronic Patient Care Report (ePCR) programmers begin to pattern the flow and content of their programs to fit the template structure for NEATs?

Will auditors begin to directly refer to this guidance when reviewing claims to tab potential overpayments? Intuitively, that would seem to be the logical next step in the process. Think of it, it invokes a sense of “We told you so” and this is what we expected or we wouldn’t have included it in the template.

Positive Step

Regardless of how this new initiative plays out, this seems to be a step in the right direction. Supporting the billing of NEATs has been nebulous and quite misunderstood between the ambulance and clinician communities for all of time. Now there is a pattern in writing.

Let’s see where this goes.

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