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A NewsletterFrom the DeskofRick MartinAugust 15, 2014Mass Health CPE ProgramOn July 11, 2014, the MA Executive Office of Health and Human Servicesissued a letter to all municipal ambulance providers announcing the AmbulanceCertified Public Expenditure (CPE) Program for Mass Health ParticipatingProviders. If you have not received this letter, the following links will bringyou to a sample of this letter (a copy of one received by a Comstar client withname redacted .) and the Excel version of the worksheet referenced in loads/2014/08/mass cpe program ploads/2014/08/provider opportunity assessment tool.xlsEOHHS has contracted with the Public Consulting Group (PCG) to assist youwith the implementation of this program.I have had some contact with PCG. They reached out to me last year withsome questions regarding the feasibility of this program knowing that Comstarwould with many municipal ambulance services in MA. The discussions werevery general. Connecticut has a similar program in place and via our CTclients, we have some familiarity with the process. The letter you havereceived appears to be the formal notification that program has started.AmericaLand of the FreeHome of the BraveBMM 9/11/2001To summarize the program in short from my understanding, there is thepossibility of additional reimbursement from Medicaid (MassHealth or welfarein MA) to the Town if the Town can demonstrate that its allowed costs exceedamounts billed.The worksheet on the last page is provided to do a self test to determine if theTown will benefit (or not) from this program.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICE8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721Mass Health CPE Program (continued)Please note, as stated in paragraph 3, if the Town formally enrolls and it isdetermined that payments actually exceed allowed costs, the town wouldhave to refund some of the Medicaid funds it received. The latter is notlikely but I would strongly advise running the numbers and doing the selftest first before enrolling with PCG. There is no harm in doing the selftest. The town would have to invest the cost accounting time to determinethe costs allowed costs per the definitions in the letter. Comstar can providethe charge information quite easily.To date, two Comstar clients have completed the worksheet and shared theresult with me. They will receive refunds in the range of 40- 50K.We are on the web atwww.ComstarBilling.comI have fielded some questions and run them by my contact at PCG. Foryour information, here are the Q/A’s to date:Q: Is the CPE Program a one shot deal?A: The program is set up to run on a recurring annual basis, and is not justa one-time event. Providers electing to participate will sign a contracteffective for as long as the CPE Program is active or until the providerterminates that contract. Providers can decide to discontinue participation atany time, effective at the start of the next cost reporting period (Providerswould still need to complete the full annual cost report and settlementprocess for the current cost reporting period, even if they elect to terminatetheir contract for the next applicable cost reporting period). Additionally, ifa provider chooses not to participate in the program this year, there will befuture opportunities to enroll.Q: Is there is minimum reimbursement requirement for this program?A: No.My contact at PCG is Anna Braet, 617-717-1371, abraet@pcgus.comBy failing toprepare, you arepreparing to fail.Benjamin FranklinPlease feel free to contact Anna with questions or me anytime via e-mailrick.martin@comstarbilling.com , or my direct line, 978-771-6482.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICE8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721We are on the web atwww.ComstarBilling.comBeneficiary Signature Requirement Positive ChangeBy: David M. Werfel, Esq.When the patient is unable to sign the form requesting payment andauthorizing the release of records due to a physical or mental condition, therequest may be executed on their behalf by a legal guardian, relative,representative payee or representative of an institution providing care.Until now, the person signing on behalf of the patient was required to alsolist their name, address, relationship to the patient and reason the patient couldnot sign.Over two years ago, I asked CMS to remove the requirement of theaddress, when one of the Medicare Administrative Contractors (WPS) notifiedambulance suppliers the address was required. The requirement of theaddress of the person signing on behalf of the patient was impractical as therewas no space on the 1500 form for it, no field for it on electronic claims, it wasnot required in the CMS Regulation (42 C.F.R. 424.36) and the industry wouldusually not be able to obtain it.By failing toprepare, you arepreparing to fail.Benjamin FranklinAfter many follow-ups, CMS has removed the requirement in .pdfIn sum, the address of the person signing on behalf of the patient is nolonger needed.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICEALS CONVERSION RATE MAXIMIZATION8 Turcotte Memorial DriveRowley, MA 01969Your service’s ALS Conversion Rate is the Total Billable Transports divided into TotalALS Billable Transports.Phone: 800-488-4351Fax: 978-356-2721The Concept: If an ALS crew is 911 dispatched in response to the callers description ofan ALS patient condition (per your policy), the transport can and should be billed at theALS level regardless of the condition found on scene.Our EMS attorney has indicated that a 3 to 1 ratio of ALS to BLS transports or a 75% ALSconversion rate, is the norm for ambulance service nationally. Anything significantlyabove that may raise a red flag with Medicare.To maximize your services ALS Conversion Rate and realize these results fully, Irecommend:We are on the web atwww.ComstarBilling.com1) E-mail me a copy of your services ambulance dispatch policy. Comstar will providefeedback and incorporate the policy into our coder documentation and training for youraccount2) Call level (BLS or ALS ) should be recorded at dispatch and assigned to theappropriately skilled crew upon dispatch.3) Your service must retain a log of the dispatch condition for each call4) Should the crew be dispatched for an ALS level condition, once on scene:I or P levelcrew member must assess the patient for the ALS condition called in to dispatch5) The PCR must identify the crew member performing the ALS assessment. The firstIntervention selection from your software’s ePCR drop down menu must be ALSAssessment. Note: this intervention may need to be added by your software provider6) The ALS assessment must also be documented in the narrative.7) If a BLS condition is found on scene after the ALS condition has been ruled out, thePCR documentation should still reflect that this is an ALS level call. Do not change theCall Type or Dispatch Level to BLS either in the dispatch log or the PCR. You maychange the treatment or transport level to BLS depending on your software.All of the above will trigger an ALS level claim submission and support the ALS charge inany denial or post payment audit situation even if no ALS skills, beyond the ALSAssessment, are performed.Based on the review of current Medicare regulations by our EMS attorney, these conceptsand this approach to billing is well within those regulations and is an established practiceamongst ambulance services (both municipal and private ) throughout the country.By failing toprepare, you arepreparing to fail.Benjamin FranklinTo initiate participation in this program, please e-mail your current dispatch policy to meat rick.martin@comstarbilling.com . I will then contact you to set up a conference callwith myself and General Manager Scott L’Abbe to review your current ALS conversionrate and the next step for maximization. Please feel free to contact me anytime withquestions via e-mail or my direct line, 978-771-6482.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICE8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721PCR CONTROLIt is best practice in the ambulance service industry to reconcile PCR totalsat least monthly to ensure all calls are documented and all billable PCR’s aresent/retrieved for billing and billed.The process to do this is outlined below:a.Every ambulance dispatch event should result in a PCRb.EMS Management Team Maintains control totals for:1. Total EMS dispatches (source dispatch system)2. Total EMS PCR’s (source your ePCR system)3. Total billable incidents(these are to or retrieved by Comstar)4. Total non-billable incidents(do not send to Comstar or designate for retrieval)We are on the web atwww.ComstarBilling.comc.Comstar will keep control totals for PCR’s received-retrievedbilled. These are currently provided to each client with eachbatch of PCR’s received/retrieved (weekly) and as part of ourmonth end report package (commitments report totals, monthly)Tie out at least monthly:b1 must b2b2 must b3 b4C must b3For clients who are enrolled in Comstar’s hosted Zoll ePCR service, thisprocess is done for you as part of that service.“Be yourself;everyone else isalready taken.”― Oscar WildeFor those clients that use other ePCR software solutions, Comstar sends aconfirmation total whenever PCR’s are received or retrieved. These controltotals are intended to be used for the above purposeTo discuss your specific situation, please contact me anytime via email,rick.martin@comstarbilling.com , or my direct line, 978-771-6482.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICEACCOUNTABLE CARE ORGANIZATONSUnder Obamacare’s Accountable Care Approach, doctors and hospitalswill be rewarded for working together to improve quality and rein in costs.8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721We are on the web atwww.ComstarBilling.comHow does the program work for the ACO?CMS will establish a budget for each ACO. The budget is based on the coststo the ACO for caring for each Medicare patient over the past three yearsplus estimated inflation. If the ACO is able to save money (reduce Medicarecosts by more than the budgeted amount) by providing higher quality care(CMS has established benchmarks to measure quality care), CMS will sharea portion of the savings with the ACO. The ACO Model does present higherlevels of rewards and risk. The ACOs could potentially lose money ifMedicare patients need more care than they have in the past, if the care is notproperly coordinated or the patient is re-admitted for the same issue. Forexample, an ACO can deny or reduce payment if the provider isn’t meetingquality standards. Also, reimbursement can be denied when a patient isreadmitted to a hospital within three days for the same problem. It’s thereforein that hospital’s interest to make sure the patient doesn’t get readmitted forthe same problem. In order to be successful, ACOs will need to put moreemphasis on post-acute care and enhance overall coordination andcommunication between hospitals, specialists, primary care physicians andrehabilitation and skilled nursing facilities. This should result in a higherquality of patient care, while eliminating duplication of services , preventingpotential future high-cost hospital services and reducing re-admittances.How does this affect EMS?To avoid such re-admittances and other quality of care issues, hospitals maypartner with the local EMS system to perform a variety of services. Thesecan include checking on the patient with home visits for the first three days,or if complications arise, transporting the patient to another level of care.There isn't a personanywhere who isn'tcapable of doingmore than he thinkshe can.Henry FordPlease let me know if your local hospital has or is planning to initiate anACO. All I need is the name an contact information for the responsibleparty at the hospital. As part of our service, Comstar’s Provider RelationsTeam will follow-up with the hospital, attain a complete understandingtheir ACO enrollment process and then present this enrollment option toyou for your review and consideration. Please send contact informationyou attain to me via e-mail :Rick.Martin@Comstarbilling.com
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICEOpen ItemsMany clients have already responded, but we still need to hear from severalclients on the following Open Items:8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721We are on the web atwww.ComstarBilling.com1) Updated BAA Agreements: This needs to be done by 9/23/13. Itis a HHS requirement for your service. There is now a BAA inWord format on our website for your use or you may use your owncompliant form. Only 38% of clients have responded to date.This is a HHS requirement of your ambulance service . Pleasetake action now. Please see page 6 of this newsletter for details.1) Rate Bundling: I am recommending this to all clients. Informationfrom recently attended EMS conferences and feedback from Chief’s,Town Administrators and Finance Directors have contributed to thefollowing talking point on why it is a good idea to bundle your ratesat this time:A. To best position your ambulance service for reimbursementunder the National Healthcare Plan (“OBamacare”) whereaccountable care organizations (ACO’s) will take a prominentrole in the reimbursement of EMS charges.B. The bundled structure creates a better match of revenue to theexpenses your service incurs to make available and provideemergency careC. Medicare (CMS) transitioned to the bundled rate structure in2002D. More than 90% of the private insurance payers we deal with areasking for claims to be submitted in a bundled structurePlease see the next page for details.Either you runthe day or theday runs you.Jim Rohn
A Newsletter from the desk of Rick Martin.COMSTARBundling Your Services Ambulance Billing RatesAMBULANCEBILLING SERVICE8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721Comstar is recommending that all clients that have not already done so,transition their rate structure from the traditional “a la carte” rate structure toa bundled rate structure during CY 2013.Bundling rates will not result in higher total reimbursement of clean claims.Increasing rates could achieve this but this is not the intent of this specificadvice. The intent here is to position your service well for the time if/whenObamacare becomes fully implemented and provider reimbursements beginto flow through Accountable Care Organizations, ACO’s, (new managedcare entities envision under the Obama plan).We advise that presenting ACO’s with a consistent and simplified feestructure that mirrors the current CMS fee schedule structure will positionyour service to attain its equitable portion of the funds allotted to the ACOfor a specific (in its totality) patient care event.We are on the web atwww.ComstarBilling.comOpportunity doesnot knock, itpresents itself whenyou beat down thedoor.Kyle ChandlerImportant Notes:1)The specific cross walk from a la carte to bundle rates will be uniquefor each client as your rates and number of a la carte charges dodiffer. Please contact me via e-mail,rick.martin@comstarbilling.com or my direct line, 978-771-6482,to discuss and map out your specific cross walk plan2)The cross walk process from a la carte to bundled is not intended toincrease your rates but must be done thoughtfully and conservativelyto ensure that your service does not unintentionally reduce its rates.Again, I can discuss crosswalk approaches that will assist you withthis process when you contact me.3)Your crews documentation and Comstar’s coding requirements arenot changed by bundleing of rates.4)The transition to bundled rates from a la carte rates is a “industry bestpractice” recommendation for the reason previously stated. It is not amandated change.CT client, obviously, stick with the state mandated rates and structure.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICEHHS-HIPAA Final Rule Compliance Deadline 9/23/13Business Associate Agreements8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721We are on the web atwww.ComstarBilling.comUnder HIPAA, your service is required to have a Business Associate Agreement(BAA) with any party with whom it shares or gives access to its patient’s PHI.Comstar meets the definition of a Business Associate of your service under HIPAA.The final rule issued on January 17th includes additional language requirementslikely not found in your current BAA. To assist you with your compliance, Withadvice from our EMS attorney. Comstar has produced a generic BAA for your use.The follow is a link this BAA: e print, fill in your service name, the date, sign and send to me for signature. Iwill then e-mail you a signed copy for your files. . All clients have a responsibilityto take action on this item. Please contact me anytime with questions. Please takenote, having a BAA with Comstar and other BAs whom you give access to yourpatients PHI is a requirement of your service that requires action by your service inorder to be compliant. If you prefer not to use the BAA offered by Comstar, pleasecontact your attorney for a BAA and send it to me for my signature. The HHSpublished date for your services compliance with this requirement is 9/23/13.Notice of Privacy PracticesThe Final Rule made some changes to the language requirements of your servicesNotice of Privacy Practices (NPP). Note, all services must have an NPP and give acopy to each patient transported.The following is a link to Comstar’s NPP. http://www.comstarbilling.com/privacy.html . Again, to assist you with compliance, and with the advise of ourEMS attorney, Comstar has produced a generic NPP for your use . The document,in MSWord format, can be found at the following link: https://www.comstarbilling.com/Documents/client npp letter.doc . For those clients whosubscribe to Comstar’s NPP mailing service, we’ve updated our forms, no action isrequired on your part.Contact me anytimewith questions on theseBAA and NPP matters.Be Nice and You’llbe happy.Dick & JackieMartinRick.Martin@comstarbilling.com or 978-771-6482
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICE8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721We are on the web atwww.ComstarBilling.comEMS Law CornerStart your PCR narrative witha description of the condition of the patient as called in to dispatch.From a billing perspective, the most severe condition encountered may bethe one described by the caller to the 911 dispatcher. The regulations allowfor billing using the most sever condition, even if that is not what is found onscene. The rational is, billing for the level of skill required and used toassess the patient condition (confirm or rule out.) that was called in to the911 dispatcher. In general, the need for an ALS Assessment is determined atthe time of dispatch based on the condition of the patient as reported todispatch by the 911 caller. Therefore, it is very important that the conditionof the patient, as called in to dispatch be both recorded in the dispatch logand used in the PCR narrative by the responding crew.The following are two items that I like to remind all clients aboutperiodically. They are very important compliance items for yourambulance service:RULE: BENEFICIARY SIGNATURE REQUIREMENTOn November 1, 2007, CMS posted the Final Rule for physicians andother suppliers. Under this rule is the Beneficiary Signature Requirement forambulance transports. Medicare regulations, specifically 42 C.F.R. §424.36,require a patient’s signature on a claim, unless the patient has died or theambulance provider/supplier can qualify for one of a number of listedexceptions. As a Medicare participating provider, the ambulance service isobligated to understand and comply with this requirement for all patient carereports used for billing Medicare.AMBULANCE PROVIDER LICENSUREANDCREW MEMBER CERTIFICATIONWell done isbetter than wellsaid.Benjamin FranklinIn order for your service to qualify for reimbursement by Medicare and otherpayers, your service must be licensed and all crew members must certified byyour state. As a Medicare participating provider, the ambulance service isobligated to understand and comply with this requirement.
A Newsletter from the desk of Rick Martin.COMSTARAMBULANCEBILLING SERVICE“Comstar supports your operations as well as billing .”Thank you for your continued business with Comstar Ambulance Billing Service. We appreciate theopportunity to provide services to you. As a company, Comstar strives to add value to all of ourclients. We have the most robust array of service options, some of which you may not be aware of.8 Turcotte Memorial DriveRowley, MA 01969Phone: 800-488-4351Fax: 978-356-2721EMT Training Course -- Practical Consideration in Drafting the PCR NarrativeThis course 2 hr training course is provided to upon request to all clients. The objectives of this courseare: To refresh and reinforce EMT’s patient care report (PCR) writing training. To refresh andreinforce EMT’s knowledge of the uses and importance of the PCR. To provide insights and guidancethat will result in improvement in the quality and usefulness of the PCR. Note: Though applicable toEMT’s in all states, this course is approved by the Commonwealth of Massachusetts Department ofPublic Health, Office of Emergency Medical Services. Massachusetts certified EMT’s can earn 2(two) credit hours of continuation credit toward their Basic, Intermediate, or paramedic certification byattending this course.Software and Data Integration Support and ServicesWe are on the web atwww.ComstarBilling.comComstar has been using the Zoll Data Systems billing software as its billing platform since 2002. Wesend and receive data in an electronic and seamless manner with existing clients using Zoll's ePCRsoftware. Comstar can also integrate seamlessly with other ePCR software vendors to the point where Iguarantee that Comstar will integrate with any ePCR solution that a client may select to use. Comstaris very flexible in this manner, because we feel it is important for you, and every client to select anePCR solution that you feel most comfortable with and best fits your needs. Our five person in-houseIT staff has successfully integrated our Zoll software with the following nine (9) EPCR softwaresolutions: AmbuPro, emsCharts, ESO Solutions, Firehouse, Healthware Solutions, ImageTrend, IMCPublic Safety, PURVIS Public Safety, and Zoll Data Systems. Given Comstar's integration guarantee,this list will grow as clients select different ePCR products. In most cases, bridge programming isrequired to make such integration successful. Comstar's IT staff performs the bridge programming atno additional cost to Comstar's clients. They also will work with your chosen ePCR software vendor,as your technical advocate, should you have any issue with their product.“Comstar provides a cost effective ePCR Solution .”Big shots areonly little shotswho keepshooting.ChristopherMorleyComstar has an ePCR Partnership Agreement with Zoll Data Systems. Ambulance services that desireto use the Zoll ePCR solution but do not have the capital resources to fund the cost of deployment,server setup and license purchase now have a cost effective alternative through Comstar. For moreinformation, please contact Jeff Tassi immediately at 800-488-4351 or JTassi@comstarbilling.com.Jeff is prepared to demonstrate the Zoll ePCR product, discuss Comstar’s capabilities to provide theweb hosted solution, present a full service outline and discuss pricing.
COMSTAR AMBULANCE BILLING SERVICE Your service's ALS Conversion Rate is the Total Billable Transports divided into Total ALS Billable Transports. The Concept: If an ALS crew is 911 dispatched in response to the callers description of an ALS patient condition (per your policy), the transport can and should be billed at the
