Friday, December 12, 2014

The End to Medicare “Back Billing”

Save the Date!
Mark this date on your calendar- February 3, 2015.

This is the date that sweeping and historic changes will take effect for the Medicare program. Late last week, the Centers for Medicare and Medicaid Services (CMS) issued the final rule on the Medicare Incentive Program and Provider Enrollment Standards. The rule has been published to the Federal Register.

The End to Medicare “Back Billing”
Readers of this space can visit our website at to view a complete overview of the changes as capsulized by the American Ambulance Association, located in the “News” section of our site. The news article contains links to the actual Federal Register posting and also includes a link to the AAA’s comments that were submitted on behalf of the ambulance industry soon after the proposed rules were first released in April 2013.

For the purposes of today’s post, we’ll focus on what we feel will be one of the biggest changes to hit the EMS billing side of our industry, the limitation of “Back Billing.”

Right now…
As it stands right now and has always been the case, a new EMS agency or one that has merged or re-created itself organizationally in some manner has always been able to notify CMS/Medicare of the changes and then seek reimbursement (once the credentialing process is completed) retroactively back to the point where the EMS agency began to transport Medicare beneficiaries (typically when the agency was licensed.)

However, other Medicare providers such as doctors and other practitioners were only able to bill Medicare equal to the time when the Medicare Administrative Contractor (MAC) received their credentialing application.

EMS agencies will now be held to this same limitation.

What does it mean?
CMS sees this changes as falling under what they refer to as a program integrity measure. They now see ambulance services as an increased risk to the Medicare program. CMS noted an “overabundance of ambulance suppliers and an overutilization of ambulance services in particular regions of the country” ergo the prohibition that currently exists for credentialing in the Philadelphia Pennsylvania metro area in addition to the Houston Texas area, as well. Also magnifying their belief is the inception of the new pre-authorization trial program for repetitive, scheduled ambulance transports in Pennsylvania, New Jersey and South Carolina.

The bottom line here is CMS is estimating this measure alone will save the program $327 million per year. That’s all anyone at the Fed level needed to hear and boom...we have new rules.

Functionally, the new EMS agency that is just beginning to operate will need to have the application in place and in the hands of the MAC the very day they begin to operate, otherwise they will be unable to collect reimbursement dollars prior to that point as the new regulations limit the effective date for credentialing to the later of (1) the date the filing of a subsequently approved Medicare application or (2) the date the enrolled provider first began providing services at a new practice location.

Location changes
Pay special attention to the last part of the paragraph above.

We frequently see EMS agencies change practice locations. It will now be vitally important that the timing of such changes with the reporting of such changes be immediate. If moving to a new station, the application to notify the MAC of this change must be immediate and basically the very day that the station change took place in order to insure no interruption of Medicare dollars to the relocating EMS agency.

This sometimes can be difficult depending on the speed of re-licensing the location with the particular State of operation and quite frankly the proper and speedy preparation of the notification application.

Along with this discussion, consider EMS agencies that may be merging and forming a new entity. Application for the new entity to not only move location, if that applies, but also to simply obtain a new Medicare provider number and be credentialed as the new incorporated entity could affect cash flow moving forward if the notification to the MAC via the filing of a correct Medicare application could have sweeping implications for what transports can be billed to and paid by Medicare based on the timing of the submission and arrival of the application in the hands of the MAC’s Provider Enrollment staff.

What can I do?
The biggest thing you can do is to stay informed. Stay on top of your changes and act immediately!

Enhanced is here to help sort out the roadmap to remain in compliance and in the green (as in money green!)

If your EMS agency is considering any of these moves, you must act immediately. The days of doing and then acting are over!

So if you are about to…
  • Move a station location (especially your base of operations but also including any sub-station
  • Merge two EMS agencies to create a new EMS agency
  • Change your company name and/or Federal Tax ID/Employer Identification Number
  • Start-up a brand new EMS agency
You need to plan ahead! Talk with someone who understands how these changes can affect your agency and have a plan up front.

Clients…let us know when things are about to change. We’ll hold your hand through the process.

Not a client? If we can help…shout out. We’ll figure it all out together!

The Ambulance Billing Services blog is brought to you by Enhanced Management Services, Inc a full-service, all-EMS, third party billing company serving clients across the United States. To learn more about the services provided by Enhanced and how they can benefit your EMS agency, visit our website at and click on the “Get Started” link on any landing page.
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