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Webinar: What's next for Ambulance Reimbursement?
January 12, 2022

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Webinar: Air Ambulance Reporting Requirements under the NSA
October 12, 2021

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Webinar: Changing the Odds by Using Strategy and Data w/Brian Choate
August 17, 2021

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Webinar: The Intersection of the Qualifying Payment Amount w/the No Surprises Act
August 5, 2021

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Webinar: No Surprises Act & Contract Negotiations
June 17, 2021

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Webinar: Enhancing Compliance and the RCM Process Through Data

April 22, 2021

QUESTIONS & ANSWERS

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Webinar: Potential Compensation Pathways from Healthcare Provisions in ARPA 2021

March 18, 2021

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Webinar: HHS Reporting Requirements

w/Asbel Montes

January 14, 2021

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Q&A

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Webinar: COVID-19 Vaccinations

w/Asbel Montes

December 1, 2020

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Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

June 17, 2020

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Questions and Answers Transcript

Has there been any further clarification about billing the HRSA Covid-19 Uninsured program for presumptive patients?


It was always under the assumption that presumptive and positive we're going to be paid. But unfortunately, that terms and conditions that you sign is for positive patients.

It has not been clarified right now. Currently, It is for positive only. There are additional avenues available for reimbursement for uninsured patients but that would be an effort at the state and local level.




Aside from HHS or PPP what other forms of relief should we be looking into?


There are 3 buckets of funding available: Payroll Protection Program, CARES Act Funding and FEMA. The CARES Act funding has a few avenues available: (1) distributions through Health & Human Services (HHS), as well as distributions through the Coronavirus Relief Fund (CRF). The CRF funds are distributed directly to state and local governments by the U.S. Treasury. These funds are available for loss revenue and increased expenses related to the Public Health Emergency. You will need to work with your state government and/or local jurisdictions to get access to these funds.




How long do we have to submit bills for uninsured COVID?


Until they run out of money and the public health emergency is over. We haven't been notified yet that they ran out of money... I would keep submitting your claims until they tell you there's no more money left available.




If we were denied for the second wave of HHS funding, can we still apply for the third wave?


I'm assuming when you mean denial that the formulary had you as a negative, so that's not really a denial. If that is what you are referencing, it just means that you did not qualify for a second level because the formula funding saw that you had already received a substantial amount of money based upon the formulary that was put together (i.e. 2% of that net operating revenue number based upon your tax filings or your balance sheet and that you uploaded your audited financials). Technically, yes, you would apply. From what I understand, it's going to be another application process.




Is there an update regarding HHS uninsured funding applying to only uninsured?  I wonder about the time period for submitting those claims and receiving dedicated funds.  Areas of the country are currently seeing spikes.


Right now, the uninsured funding is only available to those uninsured. When you read the terms and condition, you have to verify that they have no other insurance source. And, according also to Terms and Conditions you signed, it's only available to positive COVID patients. As of right now, there is no end date on that. Basically, as long as there's funds available, they are going to reimburse for the uninsured COVI-19 positive patients.




Is there any stimulus money for additional cost that we have incurred due to Covid-19?  If so, how do we apply for them?


In the next allocation, you'll see the application process open up. We're not really sure yet what the formulary is. We do understand that it is going to be looking at increased expenses aound the PPE area. Also an update to your lost revenue numbers, because you only recorded March and April and we're now into June.




Since we provided March/April lost revenue re the CARES Act, does this mean we are prohibited from claiming lost revenue from other government reimbursement sources? If so, can we seek lost revenue for other months from the Feds?


You need to have a formalized documentation system that is keeping track of all funding received due to the Public Health Emergency. This could be funding received from the Paycheck Protection Program, FEMA, HHS and any funds received from state or local government related to the PHE. Once the PHE is rescinded, you will then need to compare your lost revenue and increased expenses throughout the PHE to the revenue you received from all sources. If you have received more revenue, you will need to reimburse the federal government. If you have receive less revenue from federal sources compared to your lost revenue and increased expenses, then you will not be required to refund the federal government. Documentation will be key! Document, document, document!




When are the first CARES Act quarterly reports due?  Are there any published report specifications and requirements?


Currently, the only requirement is to submit your financial statements via the attached portal. If you have already done this through Tranche 2 funding, then nothing is due at this time. If you did not complete the application for Tranche 2 funding, you will need to follow the instructions as indicated.

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




When will be get notified if we will receive money under Tranche 2 of HHS?


You should have been notified already. If not, please call (866) 569-3522.




Will any part of the funding provided to state and local governments under the US Treasury Coronavirus Relief Fund (i.e. the $1.25 billion minimum to each state) eventually be allowed for revenue replacement?


Currently, the CARES Act direction is specific on what state and local governments can use these funds for.

The guidance clarifies what costs are permissible under the CRF, noting that necessary expenditures incurred due to the public health emergency:

  • Must be used for actions taken to respond directly to the COVID-19 public health emergency
  • May include expenditures incurred to address medical or public health needs, as well as to respond to second-order effects of the emergency, such as providing economic support to those suffering from employment or business interruptions
  • Can’t be used to fill shortfalls in government revenue to cover expenditures that wouldn’t otherwise qualify under the statute

Only certain costs not accounted for in the government’s budget most recently approved as of March 27, 2020 are permitted. Costs will, however, meet the above requirement if the cost:

  • Can’t lawfully be funded using a line item, allotment, or allocation with that budget
  • Is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation

A cost isn’t considered to have been accounted for in a budget merely because it could be paid from a budgetary stabilization fund, rainy day fund, or similar reserve account.




Will the Medicare sequestration roll back be permanent or will the 2% be back?


The Medicare sequestration roll back is temporary only and expires on 12/30/2020. It remains to be seen if Congress will make this permanent or not.




Will the Round Two Cares Act Application Portal open up again? We didn't have enough time to complete the application and want additional funding.


Round Two closed on 6/3/2020. HHS will be doing a Round 3 funding soon.




Any updates on auditing or reporting - can we just claim a revenue loss based on call volume or do we also have to show what the money was spent on?


Based upon the FAQ posted on 6/13/2020 via https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html. See the following:

Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website Tracking Accountability in Government Grants System (TAGGS). HHS is also working with the Department of Treasury to reflect the aggregate total of each recipient's attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 - PDF [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].

However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient's use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.




We have never had to submit Cost Data for Novitas, but understand it is a requirement due to the HHS funding. What format do we submit it in and where?


Please see answer above.




Traunch 3 includes all providers, including hospitals?


They're indicating it is a general allocation. And if it's a general allocation, then it would include everybody. Do not hold me to that. Remember, this is what they were thinking. They could make it a little bit more specific because the hospitals have been receiving a ton of money. And many of you have been probably talking to some of your hospital colleagues and some of them are actually sending money back because they've got way too much that they can't justify, especially in areas that may not have been hotspots that right now, if it is a general allocation, it would include all suppliers and providers of health care.




Could you please talk about the application due July 20th for the upcoming $15B HHS allocation for agencies participating in Medicaid and CHIP?


If you received funding in Round 1 or Round 2, you will not be eligible for the Medicaid and CHIP funding.




Are there any tax implications for the CARES ACT funds?


I'm going to tell you to get with your tax advisor on that. That is not my area of specialty. And there are depending upon how you have set yourself up. But I would definitely get with your tax advisor on that.




We teach EMT classes. Do these lost revenues count?


Anything related to the provision of healthcare that's related to the corona virus and pandemic would qualify. If you teach EMT classes and that was a source of revenue and because of the pandemic, you've seen a loss of EMT. And so you've seen a loss of revenue related to that. That would be a justifiable revenue loss.




If a patient becomes retroactive with Medicaid and we already received payment from the Uninsured Program - how do we go about contacting HRSA for refunds?


If at the time you validated and checked for insurance, and the patient had not insurance for a COVID-19 positive patient, then you do not need to file Medicaid if they received retroactive coverage. You just need to be able to prove under audit that when you filed you verified eligibility.





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 27, 2020

Webinar Video Replay

Questions and Answers Transcript

We have received 3 HHS Fundings and received an SBA Loan that can receive Loan Forgiveness. Are we able to get both or do we have to choose one or the other? Are they going to take back the HHS money if our SBA loan is forgiven?


The HHS funding and PPP funding are mutually exclusive; however, lost revenue and expense calculations are not. So when you are keeping record of all your expenses, you will want to back out those that were reimbursed under the PPP loan.




Is there attestation that requires signature just like in Tranche 1?


Yes. There is an attestation that has to be signed for tranche 2 funding. See link: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




If I'm receiving partial PPE supplies from our Regional Advisory Council can I still use round 3 of funding for PPE?


Round 3 funding will look at increased expenses, including PPE. If you have received funding from other sources for PPE, you should not include this in your expense calculation. You; however, could include those expenses related to PPE that were not funded by other sources.




Asbel mentioned something regarding treatment site is that correct? Now if Medicare does pay for routine follow ups will that require a PCS form? PAN numbers were extended but nothing will be billed to Medicaid if the patient has Medicare? I think the wording factors in a lot because it is not specific , I am the type that likes to dissect what I am reading: Reference COVID-19: Expanded Use of Ambulance Origin/Destination Modifiers The reason why I am a little hesitant with it all is because our biller has billed every single routine and follow up appointment run to Medicare and it just does not convince me that it is being done correctly. EX: patient went to foot Dr. for an ingrown toe nail it was billed to Medicare and now she is telling me that a PCS form is required for every DR appointment.


Medicare did not waive any medical necessity requirements. They only waived the covered destinations, regardless if an emergency or non-emergency. A physicians office is now a covered destination under the PHE. PCS requirements were not waived either; however, if related to a COVID patient and due to CDC guidance CMS did issue the following regarding PCS signatures: See FAQ from CMS starting at page 22: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf




Why is the there a delay in payments from the Cares Act provider Relief distributions?


Due to the continued pressure the administration is receiving regarding the methodology on how they are distributing payments, they have increased pressure to ensure that the money is going to the individuals that need it. As the saying goes, with speed comes lack of precision. In order to keep the money flowing quickly it may not be as precise as many would like. They have instituted a few safeguards for a quality review of payments over a certain threshold. If you have not received funding in the 2nd tranche yet, it may be do to that or there could have been something regarding your inputs into the application that triggered a review as well. They will be rolling out funding in waves every Friday or you may receive a letter asking for additional information.




Can all of PPP funds be used for payroll? More than 75%?


Yes but not less than 75% for it to be forgiven.




How do we get transport to alternate destinations and telemedicine payments to be permanent for EMS?


This will take advocacy by our industry. The good thing is that CMS Administrator Seema Verma and HHS Secretary Alex Azar are on the record, on numerous occasions, that they expect to make many of the waivers permanent. However, we need to keep our grassroots advocacy up to make these waivers permanent.





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 5, 2020

Webinar Video Replay

Questions and Answers Transcript

If the Ambulance Service is Out of Network and no benefits paid, can we submit through the COVID Claim CARE Act portal?


This is for individuals who are uninsured (not uncompensated care). The intent of the uninsured dollars that were appropriated here were for individuals that did not have any insurance at all. However, if it is COVID related, there are some tweaks in there regarding deductibles. Some of you indicated that in some areas some insurance carriers are not paying anything for out of network. There has been sufficient pressure from some insurance commissioners in some states that has put pressure on those networks that it doesn’t matter if it is in or out of network, they should cover as if it was in network. You should not put that in and attest that it is an uninsured patient because if you do, technically you are falsifying the attestation. I suggest you work with your local insurance commissioner through these schematics because it has been successfully overturned in other states.




If we bill insurance and the charges are denied as non-covered, can we submit through the COVID Claim CARE Act portal?


I am questioning the non-covered for a COVID related patient based upon these nuances where many of your large major health payers are actually covering these treatment services. If it was an early date of service (before February 4) I would suggest get with the health plan who denied as non-covered to reprocess the claim. You shouldn’t technically have non-covered under the conditions of how this uninsured COVID related portal is going to work. This portal is only for patients who do not have insurance. You need to have a separate process for COVID and non-COVID related in case there is a processing error.




Could you clarify the need/use for special modifiers such as CS and CR?


This question is looking for guidance around Medicare/other payers wanting to use the CR for all COVID related claims. The CS is a modifier that will waive copays and deductibles. The CR modifier should be on all Medicare claims for COVID presumptive and COVID related claims as a tracking mechanism for Medicare. The CS modifier is a waiver. I heard from two different Medicare Administrative Contractors (MAC) that they are waiving it. I should know by Thursday if the CS modifier is appropriate to waive those copays. I do understand that there are two MAC’s that are suggesting ambulance services use the CS modifier to waive the copay and deductible; I have not been able to confirm this yet, but should have confirmation by Thursday of this week and can follow up with you on that.




For public government agencies who are registering for COVID-19 uninsured patient portal we are getting stuck at the very beginning where it asks for the Medicare ID and the tax classification. Typically we select “other” and then identify ourselves as government or municipality, etc. It does not give us this option. What recommendation do you have on this as we cannot continue?


I have not heard feedback yet regarding this. I did get receive feedback that they are following up on this issue to figure out a work around. I hope to have an answer by this evening on how to navigate through this issue.




Is the portal only for confirmed COVID or can you also submit suspected?


I have not asked this question yet because it can be perceived in the instructions that it includes both. It can also be perceived that it only includes those that are confirmed by using the U code after 4/1 or the B code prior to 4/1 depending on how you are reading the instructions. As a general rule for what I am doing, I am going to be submitting both at this time through the uninsured portal as I do not want to ask at this time since it can be interpreted both ways.




Will the treated in place (aka Treated not transported) be eligible for billing to HRSA for non-insured patients?


At this time, no, as they are only paying for services that are currently covered under the Medicare fee for service program. If it is a non covered service, it will not be under the uninsured.




Can non-hospital based private ambulance services bill through the HRSA website?


Absolutely, you can! This is open to everyone. Direction on governmentals should be available later this evening. If you haven’t registered, I suggest you do so today, as it is at least a two day process for you to be authenticated.




What is the timeframe from application to receipt of Tranche 2 provider relief funds?


Once your application is approved, they will distribute the funds every Friday as they receive/approve applications. It is anticipated and expected that many who applied should start to see the funding this Friday and every subsequent Friday until all approved applications are funded.




How specific do the patients’ complaints need to be to be considered a suspected COVID patient?


There has been CDC guidance that was given on how the questions to ask a patient to determine if they are a suspected COVID patient. I am assuming you are not using this guidance.




If you accept the first and second round of funding, how long do we have to not balance bill presumptive or positive COVID patients?


Most of the emergency rules/guidance is throughout the public health emergency. Once the PHE has been rescinded by the President of the United States, that is typically when everything ceases on the requirements from some of these waivers.




Insurance companies are still applying co-pays and deductibles when you use the Z correlated diagnosis Codes when you suspect somebody has COVID. Please advise.


I am assuming that an insurance company has indicated to you that they are waiving copays and deductibles for suspected COVID patients. The first thing you need to do is, did you follow the requirements as outlined by the health plan? If you did, then you need to engage the health plan. If you did not, then you need to correct your billing practices to do that. The second thing is, if you had followed those guidelines, you need to determine if ambulance service is included. I know just because there was guidance given by many of the health plans, I followed up with every single one of them to ensure that ambulance services were included in that guidance. I am suggesting to you to not take it they are intentionally excluding you; if you call them, they may have not realized they didn’t include you in it and need to modify.




The HHS portal for the uninsured (apparently linked with Optum Pay/United HealthCare) seems to be lagging (unless I did it wrong). I registered last week and I am getting various emails one time it states in process, then it states our ACH has been processed, then it later states it’s been changed back, etc. I called, they tell me it takes 7-14 days to finalize the process and it shows I am ok. Has this been the norm?


You are the first to report this to me. I am going to note this; if anyone else on the line has this concern as well, please email us so we can track it and follow up/report this issue.




When reporting Tranche 2, I understand there are many ways to look at the data but wanted to confirm they are only asking that you estimate your revenue loss for March and April only (not a full year of expected loss).


You are correct. They are only looking at March and April and it is an estimate. Remember that in an estimate you need to be able to justify. For some people who have relatively little growth year after year, it might be appropriate to compare where you were in March/April of last year to March/April of this year. Utilize a comparative pre-COVID quarter/month/year to what you would have anticipated had COVID had not happened to estimate that loss down to the March/April. Under an audit, you need to be able to prove your estimate.




We asked HRSA and were told that governmental entities should check the S core box and then check the state local government box below. Are you hearing this?


I have not heard this; if this is what they are telling you, this may be the solution but I haven’t been able to confirm yet. I hope to have an answer by this evening.




Would paying hazard pay bonuses to employees be a forgivable expense under the PPP?


Under the PPP, it is any cash, wages or money that is paid to an employee may be used for the purposes of the PPP funds. My suggestion is to make sure you document of any hazard pay/differential. Make sure you utilize the Department of Labor and Labor Standards Act weighted average overtime calculation should those individuals have hazard pay where they might have different rates of pay.




Does the HHS funding have an Expiration date to it as to when we are no longer required to accept the terms?


Typically, the terms and conditions would go through the PHE cycle.




Does the revenue loss estimate only apply to ambulance, or is this a general requirement for all providers including hospitals?


This number applies for any applicant for the 2nd tranche funding request for all healthcare providers and suppliers that do not do cost reporting. I am unsure what the “verification” process is for those providers that do cost reports.




The Terms and Conditions of the uninsured lead us to believe it's only for the Positive patients. Would this trump the instructions?


The T&C is unclear. I agree it “leads you to believe it is only for Positive patients”; however, it is not clear and there is an argument for ambulance services who do not diagnose patients that presumptive could be included. My suggestion is to submit uninsured claims for reimbursement that are presumptive and positive for reimbursement.




Please share the link to the sample form of the uninsured COVID-19 claims.


https://coviduninsuredclaim.linkhealth.com/claims-and-reimbursement.html





Virtual Town Hall w/Asbel Montes

Cutting Through the Noise

April 22, 2020

Webinar Video Replay

Navigating Reimbursement During the Next 90 Days of COVID-19 w/ Asbel Montes

April 8, 2020

Webinar Video Replay

Questions and Answers Transcript

We have received 3 HHS Fundings and received an SBA Loan that can receive Loan Forgiveness. Are we able to get both or do we have to choose one or the other? Are they going to take back the HHS money if our SBA loan is forgiven?


The HHS funding and PPP funding are mutually exclusive; however, lost revenue and expense calculations are not. So when you are keeping record of all your expenses, you will want to back out those that were reimbursed under the PPP loan.




Is there attestation that requires signature just like in Tranche 1?


Yes. There is an attestation that has to be signed for tranche 2 funding. See link: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




If I'm receiving partial PPE supplies from our Regional Advisory Council can I still use round 3 of funding for PPE?


Round 3 funding will look at increased expenses, including PPE. If you have received funding from other sources for PPE, you should not include this in your expense calculation. You; however, could include those expenses related to PPE that were not funded by other sources.




Asbel mentioned something regarding treatment site is that correct? Now if Medicare does pay for routine follow ups will that require a PCS form? PAN numbers were extended but nothing will be billed to Medicaid if the patient has Medicare? I think the wording factors in a lot because it is not specific , I am the type that likes to dissect what I am reading: Reference COVID-19: Expanded Use of Ambulance Origin/Destination Modifiers The reason why I am a little hesitant with it all is because our biller has billed every single routine and follow up appointment run to Medicare and it just does not convince me that it is being done correctly. EX: patient went to foot Dr. for an ingrown toe nail it was billed to Medicare and now she is telling me that a PCS form is required for every DR appointment.


Medicare did not waive any medical necessity requirements. They only waived the covered destinations, regardless if an emergency or non-emergency. A physicians office is now a covered destination under the PHE. PCS requirements were not waived either; however, if related to a COVID patient and due to CDC guidance CMS did issue the following regarding PCS signatures: See FAQ from CMS starting at page 22: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf




Why is the there a delay in payments from the Cares Act provider Relief distributions?


Due to the continued pressure the administration is receiving regarding the methodology on how they are distributing payments, they have increased pressure to ensure that the money is going to the individuals that need it. As the saying goes, with speed comes lack of precision. In order to keep the money flowing quickly it may not be as precise as many would like. They have instituted a few safeguards for a quality review of payments over a certain threshold. If you have not received funding in the 2nd tranche yet, it may be do to that or there could have been something regarding your inputs into the application that triggered a review as well. They will be rolling out funding in waves every Friday or you may receive a letter asking for additional information.




Can all of PPP funds be used for payroll? More than 75%?


Yes but not less than 75% for it to be forgiven.




How do we get transport to alternate destinations and telemedicine payments to be permanent for EMS?


This will take advocacy by our industry. The good thing is that CMS Administrator Seema Verma and HHS Secretary Alex Azar are on the record, on numerous occasions, that they expect to make many of the waivers permanent. However, we need to keep our grassroots advocacy up to make these waivers permanent.