Table of Contents

Hospital Repeat Admission and Interrupted Stay Update

2007 AAA Medicare Rate Calculator & Forecasting Tool Now Available

Submit Your Ambulance Cost Survey Today

Reminder: Details of Next Ambulance Open Door Forum

Raids of Ambulance Services in Texas

House Democrats Recommend New Committee Assignments

Hospital Repeat Admission and Interrupted Stay Update

By Brian Werfel, Esq.

We wanted to update you on a new development related to the hospital repeat admission/interrupted stay issue. It has come to our attention that Carriers are now sending out overpayment letters for trips going back to 2002, claiming that these patients were hospital inpatients on the date of the ambulance trip.

This is occurring in states around the country, not just California , Florida and New York , where overpayments have been identified by Recovery Audit Contractors. We suspect that CMS has instructed the Carriers to seek overpayments retroactive to 2002. If you have not already received these overpayment notices, you should be on the lookout for them.

The overpayment notice will not give you the exact reason the overpayment was assessed, e.g., whether it was a repeat admission or an interrupted stay. It will simply tell you that Medicare records show that the patient was a hospital inpatient on the date of service.

We have seen examples of errors by the Carriers, including:

* hospital to hospital transfers (i.e. discharge/admission) for an elevated level of care.

* situations where the hospital had the wrong discharge or admission date. This typically occurs when the admission or discharge date is close to midnight.

* situations where the ambulance service has previously refunded the money to Medicare (e.g. where they learned after the fact that the facility was responsible).

For this reason, it is important that you research each claimed overpayment. To do this, you will need to contact the hospitals and nursing homes, so you can determine "inpatient" status on the date of service. For trips to the Long Term Care Hospital, you will need to account for the patient's whereabouts going 3 days back (including the date of the transport); for transports from the LTCH, you will need to account for the patient's whereabouts 3 days forward (including the date of transport). For all other trips, you will only need to look 1 day in each direction.

In sum, (1) any transport to or from an acute care hospital requires an analysis as to whether it was a repeat admission and (2) any transport to or from a psych, rehab or LTCH requires an analysis as to whether it was an interrupted stay.

We also recommend you check to make sure you have not previously refunded the money to the Carrier.

As a reminder:

* a repeat admission occurs when the patient is discharged from an acute care hospital and returns to the same acute care hospital on the same day for treatment of the same condition.

* an interrupted stay occurs when the patient is discharged from an LTCH, rehab or psych hospital and returns within a certain period of time (typically 3 days, but longer for LTCHs). You should be billing the hospital (not Part B) if the patient:

* is discharged from a LTCH and returns before midnight on the third calendar day (i.e. discharged on Monday and returns before midnight on Wednesday)

* is discharged from a psych hospital and returns on the same day

* is discharged from a rehab hospital and returns on the same day

2007 AAA Medicare Rate Calculator & Forecasting Tool Now Available

The 2007 version of the "AAA Medicare Rate Calculator & Forecasting Tool" is now available on the AAA website and is free to AAA members. The Forecasting Tool is designed to assist AAA members in calculating and verifying Medicare ambulance fee schedule rates and in developing projections for future Medicare reimbursement. We strongly recommend prior to the beginning of 2007 to compare the rates published by your Medicare carrier or fiscal intermediary with those of the Tool. This will help ensure there are no discrepancies in the published rates and that your operation is receiving the correct reimbursement amount.

The rates of the Medicare Rate Calculator & Forecasting Tool take into account the ambulance relief included in the "Medicare Prescription Drug, Improvement and Modernization Act" (MMA). The rates also reflect any recent Medicare policy changes or fee schedule adjustments for 2007 including the 4.3% inflation update. All you need to do is enter a zip code and the Tool will automatically do all the calculations for you.

To access the Tool, go to the AAA website at www.the-aaa.org and click on the link entitled "2007 Medicare Rate & Forecasting Tool". You can also access the Tool at: http://www.the-aaa.org/industryissues/reimbursement/2007MedicareRateCalculator.htm . You will be asked your username and password to be able to download the file.

Submit Your Ambulance Cost Survey Today

As of this Friday, Quantria Strategies will no longer accept surveys submitted as part of the AAA ambulance cost study. The survey is open to all AAA members and we strongly encourage your operation to complete and submit an ambulance cost survey. The study is essential so that the Association will have data to compare to the results of the ambulance cost study being conducted by the Government Accountability Office (GAO). The GAO is expected to release the results of their study early next year. Please submit your survey by December 15.

The AAA contracted with Quantria Strategies, LLC to conduct the survey and only their representatives, John O'Hare and Judy Xanthopoulos, and our data analyst, Chris Hogan, will see the individual data. Participation is voluntary, of course, but responses from operations such as yours are critical if the survey is to accurately reflect the experiences across the range and diversity of all providers. Please therefore take the time to complete and submit a survey.

Any and all responses you provide to assist in this effort will be CONFIDENTIAL and not shared with the AAA leadership or staff, any private organization or government entity. Our data analyst will only report information in the aggregate.

To complete this survey, please follow these instructions:

•  Access the Internet website for the survey at www.ambulancecoststudy.com and click on "Survey" on the left hand side of the homepage;

•  You will be directed to the survey log-in and asked to provide a username and password. The login information is provided below;

Username: AAAMEMBER

Password: 10001

•  Download the survey, which is an Excel spreadsheet, on to your computer;

•  Compete the survey to the best of your ability; and,

•  Once it is completed; e-mail the survey to info@ambulancecoststudy.com no later than December 15, 2006.

For those AAA members who received a letter, e-mail or phone notification about being part of the random sample and have yet to submit a survey, please use the username and password contained in the e-mail or letter to access the survey.

We hope you will take the time to participate in this important project. With your help, we will be able to provide the Congress with information necessary to ensure that your organization is fairly and adequately compensated for providing critical, life-saving ambulance services to Medicare patients. If you have any questions, please e-mail John O'Hare or Judy Xanthopoulos at: info@ambulancecoststudy.com .

Reminder: Details of Next Ambulance Open Door Forum

The Centers for Medicare and Medicaid Services ( CMS ) announced that the next Ambulance Open Door Forum will be held on Tuesday, December 19 at 2:00 p.m. (eastern). To participate in the Forum, dial 1-800-837-1935 and provide the operator with the conference ID number of 7362106 and your name, organization name and the state from which you are calling. Below are more details on the Forum.

CMS Ambulance Open Door Forum

Date: Tuesday, December 19, 2006

Time: 2:00 to 3:00 p.m. (eastern)

Conference Call Number: 1-800-837-1935

Conference ID: of 7362106

Conference Leaders: Dr. Bill Rogers/Dr. Charlotte Yeh/Natalie Highsmith

TTY Communications Relay Services are available for the hearing impaired. For TTY services dial 7-1-1 or 1-800-855-2880 and for Internet Relay services click here http://www.consumer.att.com/relay/which/index.html . A relay communications assistant will help.

ENCORE: Call Number 1-800-642-1687; Conference ID Number of 7362106.

"Encore" is a recording of this call that can be accessed by dialing 1-800-642-1687 and entering the Conference ID number of 7362106. You can access the recording of the call from Tuesday, December 19 after 5:00 p.m. (eastern) through Friday, December 22.

Raids of Ambulance Services in Texas

By David M. Werfel, Esq.

On December 6 and 7, 2006, federal and state agents from a very large task force that included many agencies, executed search warrants at several ambulance companies (early indications are 11 companies) in Texas, mostly in the Dallas area, for Medicare and Medicaid fraud.

The cases seem to be centered on dialysis transports, but there are other issues, e.g. large discounts to facilities, overbilling, etc.

The raids on December 6th were simultaneously executed pursuant to search warrants. Some arrests were also made at that time.

From all indications, none of the targets of the investigation are members of the American Ambulance Association.

House Democrats Recommend New Committee Assignments

Yesterday, the Democratic Steering Committee made recommendations for new committee assignments including Ways and Means and Energy and Commerce which are the two Committees that oversee Medicare and Medicaid policy.

The new members of those two committees are:

Ways and Means Committee:

• Congressman Earl Blumenauer of Oregon
• Congressman Ron Kind of Wisconsin
• Congressman Bill Pascrell of New Jersey
• Congresswoman Shelley Berkley of Nevada
• Congressman Joe Crowley of New York
• Congressman Kendrick Meek of Florida
• Congressman Chris Van Hollen of Maryland
• Congresswoman Allyson Schwartz of Pennsylvania
• Congressman Artur Davis of Alabama

Energy and Commerce Committee:

• Congresswoman Jane Harman of California
• Congressman Leonard Boswell of Iowa
• Congresswoman Darlene Hooley of Oregon
• Congressman Anthony Weiner of New York
• Congressman Jim Matheson of Utah
• Congressman G.K. Butterfield of North Carolina
• Congressman Charlie Melancon of Louisiana
• Congressman-elect Baron Hill of Indiana

The full Democratic Caucus will vote on these nominations. For a complete list on new committee assignments, please go to: http://democraticleader.house.gov/press/ .

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