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CMS Publishes Final Rule on Scheduled, Repetitive PCS Forms

As expected, the Centers for Medicare and Medicaid Services (CMS) published a Final Rule today amending the regulation for scheduled, repetitive transports.  Effective January 1, 2013, the regulation will state: “The presence of the signed physician certification statement does not alone demonstrate that the ambulance transport was medically necessary.”  This revision effectively takes away the ambulance industry’s ability to argue that validly signed Physician Certification Statements (PCSs) for scheduled, repetitive transports should establish medical necessity.

The Rule makes clear that ambulance services cannot solely rely on a PCS to establish medical necessity for any non-emergency transport. Regardless of what a PCS might state, providers must document the condition of the patient as they observe it and only bill for services when all of Medicare’s requirements have been strictly met.  Click HERE to read CMS’s comments on the repetitive PCS regulation revisions.

This Rule also updates the regulations to include the extension of the temporary 2% urban, 3% rural and 22.6% super-rural bonus payments enacted under the Middle Class Tax Relief and Job Creation Act of 2012.  Those bonus payments will expire at the end of this year.

HHS Gives States More Time to Decide on Their Exchanges

Today was also supposed to be the deadline for states to tell the federal government whether they wanted to establish their own health insurance exchange under the Healthcare Reform Law.  But last night, the Department of Health and Human Services (HHS) decided to extend the deadline until December 14, 2012.  This is the second extension in a week and it came in response to a letter from the Republican Governors Association requesting additional time.

The state health insurance exchanges are a linchpin of the Healthcare Reform Law because they are the vehicle through which a large number of currently uninsured Americans could obtain qualifying health insurance.  Open enrollment in these exchanges is supposed to begin in October 2013, with coverage starting January 1, 2014.  If states do not set up an exchange, the federal government will set up an exchange for them.  Or, states have the option of running an exchange in partnership with the federal government.  As of yesterday only 16 states and the District of Columbia have said they would set up their own exchanges.

We are monitoring the latest developments and will have a full update at the abc3 conferences this spring.