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CMS Issues Transmittal on Corrected 2006 Rates
By David M. Werfel, Esq., AAA Medicare Consultant

Please Help The AAA Relieve Your Paperwork Burden

AAA Lobby Days A Huge Success!!

CMS Posts Documents on Electronic File Interchange Process for NPI

CMS Issues Summary of 2006 Ambulance Fee Schedule
Forwarded from CMS

CMS Issues Transmittal
on Corrected 2006 Rates
By David M. Werfel, Esq., AAA Medicare Consultant

On February 10, 2006, the Centers for Medicare and Medicaid Services (CMS) sent to carriers and fiscal intermediaries the Transmittal 852 (Change Request 4362). On February 14, CMS made public the transmittal and it can be downloaded from the CMS website at: http://www.cms.hhs.gov/Transmittals/Downloads/R852CP.pdf

This transmittal contains the information that CMS provided to the AAA on February 7 and included in the AAA Member Advisory issued later that day. The transmittal contains no new information. In summary, it provides carriers and fiscal intermediaries with the corrected Medicare fee schedule rates for 2006. While the document gives carriers until February 24, 2006 to implement the corrected rates, the reality is that carriers have already loaded, tested and started paying claims.

CMS has not yet advised carriers how to recover the overpayments for claims paid at the incorrect rates. As soon as the AAA receives that notification, we will advise you.

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Please Help The AAA Relieve Your Paperwork Burden

As reported yesterday in an AAA Member Alert, on January 27, 2006, CMS published a notice in the Federal Register seeking public comment on proposed revisions to the Medicare provider enrollment application (855 Form). Among the proposed revisions is the elimination of the requirement that ambulance companies notify CMS of any changes in crewmembers. Unfortunately, the proposed revisions would retain the requirement that CMS be provided with information about each vehicle. As companies are required to register all vehicles with existing state and local agencies, the requirement that companies also register these vehicles with CMS is duplicative and unduly burdensome on companies.

For this reason, we strongly urge all AAA members to respond favorably to the decision to remove the crewmember notification requirement, and to recommend that CMS further remove the vehicle requirements . Attached to this E-Update is a sample response letter (however, we encourage companies to customize this letter to their own situation) for you to submit on the notice. The Office of Management and Budget must receive all comments by February 27, 2006. Please mail your comments to:

OMB Human Resources and Housing Branch
Attn: Carolyn Lovett, CMS Desk Officer,
New Executive Office Building
Room 10235
Washington, D.C. 20503

AAA Lobby Days A Huge Success!!

We had a great turnout last week for our first AAA Lobby Days in several years with 55 attendees representing 35 states. The event was very timely with Members of Congress having just returned to Capitol Hill for the 2 nd Session of the 109 th Congress and the release last Monday of the President's FY 2007 Budget Proposal. The attendees met with their Members of Congress and congressional staff on Medicare ambulance relief and including ambulance services in the Stafford Act.

As a result of the congressional meetings, attendees received numerous commitments from Members of Congress to cosponsor the Medicare Ambulance Payment Reform and Rural Equity Act  (S. 1109, H.R. 2014).  A handful of Members of Congress have already followed through with their pledge and officially cosponsored the bill.  On the Senate Bill (S. 1109), Senators Barbara Boxer (D-CA), Thad Cochran (R-MS), Blanche Lincoln (D-AR) and Ken Salazar (D-CO) have been added as cosponsors and on the House Bill (H.R. 2014) Rep. John Sweeney (R-NY) is now a cosponsor. 

We also made great progress in gaining support for including ambulance services in the Stafford Act. The Stafford Act is the federal statute on the determination for FEMA reimbursement for services provided during a federally declared disaster.  While ambulance services are eligible for FEMA reimbursement, providers often face opposition from local, state and federal government officials regarding eligibility because ambulance services are not specifically listed in the Stafford Act.

We want to thank those individuals who attended this year's event and encourage everyone to participate in our next AAA Lobby Days.

CMS Posts Documents on Electronic File Interchange Process for NPI

Earlier this week, CMS posted several documents on the process for the Electronic File Interchange (EFI). EFI, which is also referred to as "bulk enumeration," is a process by which a health care provider or group of providers can have a particular organization known as an Electronic File Interchange Organization (EFIO) apply for National Provider Identifiers (NPI) on their behalf. The EFI documents include a summary, user's guide and technical companion manual and can be accessed at the CMS website for NPI at: http://www.cms.hhs.gov/NationalProvIdentStand .

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that the Secretary of Health and Human Services adopt a standard unique health identifier for health care providers. On January 23, 2004, the Secretary published a Final Rule that adopted the National Provider Identifier (NPI) as this identifier. 

All HIPAA covered healthcare providers, whether they are individuals or organizations, must obtain an NPI for use to identify themselves in HIPAA standard transactions. Once enumerated, a provider's NPI will not change. The NPI remains with the provider regardless of job or location changes.

IPAA covered entities such as providers completing electronic transactions, healthcare clearinghouses, and large health plans, must use only the NPI to identify covered healthcare providers in standard transactions by May 23, 2007. Small health plans must use only the NPI by May 23, 2008.

CMS Issues Summary of 2006 Ambulance Fee Schedule
Forwarded from CMS

Ambulance Fee Schedule
Section 1834(l)(3)(B) of the Act provides the basis for updating payment limits for ambulance services.  Specifically, this section provides for an update in payments for 2006 that is equal to the percentage increase in the consumer price index for all urban consumers (CPI-U), for the 12-month period ending with June of the previous year.  The resulting percentage is referred to as the Ambulance Inflation Factor (AIF).  The AIF for calendar year 2006 is 2.5 percent.

The national fee schedule for ambulance services has been phased in over a five-year transition period beginning April 1, 2002.  The Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) also established that for ambulance services furnished during the period July 1, 2004 through December 31, 2009, the ground ambulance base rate is subject to a floor amount, which is determined by establishing nine fee schedules based on each of the nine census divisions, and using the same methodology as was used to establish the national fee schedule.  If the regional fee schedule methodology for a given census division results in an amount that is lower than the national ground base rate, then it is not used, and the national fee schedule amount applies for all providers and suppliers in the census division.  If the regional fee schedule methodology for a given census division results in an amount that is greater than the national ground base rate, then the fee schedule portion of the base rate for that census division is equal to a blend of the national rate and the regional rate.  For CY 2006, this blend would be 40 percent regional ground base rate and 60 percent national ground base rate.  Prior to January 1, 2006, during the transition period, the AIF was applied to both the fee schedule portion of the blended payment amount (both national and regional (if it applied)) and to the reasonable cost or charge portion of the blended payment amount separately, respectively, for each ambulance provider or supplier.  Then, these two amounts were added together to determine the total payment amount for each provider or supplier.  As of January 1, 2006, the total payment amount for air ambulance providers and suppliers will be based on 100 percent of the national ambulance fee schedule, while the total payment amount for ground ambulance providers and suppliers will be based on either 100 percent of the national ambulance fee schedule or 60 percent of the national ambulance fee schedule and 40 percent of the regional ambulance fee schedule.

For more information, go to ambulance fee schedule page on the CMS website at: http://www.cms.hhs.gov/AmbulanceFeeSchedule/02_afspuf.asp .

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