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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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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

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 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

The Governor put out Executive Order #2020-39. Our governor has issued an EO addressing EMS. She has lessened the staffing levels across the board. Will the insurance companies still reimburse with lower staffing levels that have been approved by our state? IE ALS = Paramedic + MFR is now allowed.


There is an Executive Order regarding licensing, which will be your best friend. It is a really good move for your Governor to put in an executive order relaxing their credentialing requirements that make up either an ALS or BLS call. As long as you have an EO relaxing it, still allowing it to still be an ALS, then MCR, MCD and Commercial Payers will reimburse you, unless you have very specific contracts that actually list exactly who it is that makes it one; most people follow local and state guidelines as it deals with credentialing, as long as your contract indicates that, the EO will be allowed for you to continue to bill as long as you are following within those parameters.




Any consideration of this on the Ambulance Cost Report?


Unfortunately, because we do not do ambulance cost reports right now, they are looking at the spend. This public health emergency will not be a factor in any funding that we would currently receive right now. If that did not answer your question, please follow up.




On the Accelerated/Advance payment, current claims will be paid and the recoupment will not take place until 120 days from the date the advance payment was made. Is this correct?


That is absolutely correct. Under this PHE it is usually 90 days, but they will give you 120 days from the date that you get paid before doing the recoupment. It is my understanding that they will work with you on a schedule; you will want to work on that with your MCR Administrative Contractor.




What if you are a for-profit entity but as a JV with a non-profit hospital?


If you are a for-profit entity, you should be working with that nonprofit hospital entity on how they are requesting public assistance from FEMA; you directly cannot directly go to FEMA, but you should be able to go through your hospital since you have a JV with the non-profit hospital.




Will there be any CARES funding for entities that have an affiliation with an entity with greater than 500 employees?


This is going to the PPP program and economic injury components of it. We are actively working on this as an industry to get the affiliation requirements modified to allow for the NAICS industry code to include ambulances in the over 500 employees. We are actively advocating this and have the ears of leadership on Congress, who understands the issue. As you probably heard from leadership, they want to put an additional 325 Billion to 350 Billion additional dollars into the Small Business Package. If we can get this nuance in there, it will take care of this question. I suggest you all reach out to your local delegation to help them understand that urgency.




Is there any talk of CMS covering A0382?


No. What we are asking for at this point in time, is from the regulatory side of it that they can possibly pay for COVID related claims at the ALS base rate. On the statutory side, we are asking for an economic stimulus package that we get a 20% add on payment for ALL Medicare transports happening through this PHE (not just COVID transports) retrospective to 3/1.




MOST of the ICD10 COVID codes are specific to COVID - most of our transports coming out of the hospital state "possible COVID" - test results aren't back yet - how do we use the ICD10 codes when we don't have a COVID diagnosis?


Your primary should be whatever condition they are complaining about and why you’re picking them up, your secondary code should be the Z code if they are possible COVID; there are payers rejecting them due to not being medically necessary if they don’t have the Z code. Get with them to create some clarification waivers. Your local lobbying can do a lot of good for you at this level. Humana, Cigna and Aetna have come out with specific guidance on how they will handle.




Has CMS made a decision on signatures for transport services?


In the last CMS waiver guidance, they gave direction on this, but did not include ambulance. In the next waiver, we should see clarification on this for ambulance. In the meantime, use a common sense approach. When CDC has issued guidance stating we need a 6ft distancing process, we obviously can’t get a signature with an iPad or electronic medical record. Use your due diligence and make note that this is a COVID (or presumptive) related transport/patient.




We are receiving multiple calls and requests from patients living at home who have lost their POV/Community w/c transportation to dialysis. Is there a way to transport them by ambulance and bill?


We are currently looking in to this. It will be based upon your region. Document, document document. Use common sense approach. You will need to be able to show that it was logical and necessary to provide this transport.




What if you are a not for profit ambulance service?


You will need to first reach out to your local Emergency Management Department, or appropriate State Emergency Management representative to apply for Public Assistance Funding.




Any word on if CMS will delay cost reporting for those agency's that have been chosen to report this year?


As of now, cost data collection has not been waived. As you can imagine, CMS is currently only processing waivers related to COVID-19 and since data collection is not required until 5 months following end of your fiscal year reporting period if you were selected in round 1, we do not expect anything on this in the near future. It should be noted that there is already the ability to request an exemption in reporting due to a hardship.




You mentioned 20% increase for COVID-19 related claims. Do you recommend a separate Claim charge or a global increase?


We are recommending a 20% add-on payment for all Medicare transports during the Public Health Emergency declaration. A typical add-on payment would be for the base rate and mileage for each claim. Note: the request is for all Medicare transports and not just COVID-19 related. We may have to negotiate to reimburse only COVID-19 related claims but the ask is for all Medicare claims at this time.




Has there been any direction regarding direct billing for treatment in place or Telehealth for EMS agencies?


At this time we are still working with CMS for a waiver on reimbursement for the response to a call and treating the patient in place. We are also working on legislation to be passed in Stimulus #4 that will allow for treatment in place in the event we are not successful with CMS. It appears CMS and the Office of General Counsel believe they do not have the statutory authority to allow for payment for the treat in place since Medicare payment policy is a transport benefit only for ambulance providers and suppliers. We disagree with their interpretation and are working with CMS leadership.




What is the turn around time under the Accelerated & Advanced Payments Program for MAC to process the payments?


It usually takes 2 - 3 weeks but they are turning around the requests within 5-7 days. You will want to apply through your MAC.




HHS Grant Program. $30BN released and 0.86% allocated to EMS totaling ~$258MM. Is this available to both public & private services? If so, how do we apply?


According to the press release, there is no application for this original $30B disbursement. It will be deposited directly. We are still waiting on the when and how. Stay tuned.




If you are a Private For Profit EMS Agency that provides 911 services for multiple Counties, would you have to go through each county individually on FEMA opportunities, and if so would you have to apply through the County Commission, or could you also qualify through the 911 center itself?


I would suggest you try and do a state contract through FEMA. If the state is unwilling to do a global contract, I would do the 80/20 principal and work with those locations that have the largest COVID-19 related expenses.