Ability of ALS Level Providers to Bill for ALS Assessment Recently a mini-survey was conducted regarding the ability of ALS Level providers to bill for "ALS Assessment." I received a total of six (6) responses, and the "Survey Sheet" is included below. This was run for a week 01/09/07-01/16/07. The last response was received on 1/09/07. Our conclusion is that yes, EMS Provider Services can bill for an ALS assessment; however, certain conditions must be met: 1. The 9-1-1 call should have been EMD'd to assure that an ALS response was required. 2. With #1 above, there should be (in place) a QA/QI program. 3. ALS assessment can be billed; however, the patient must be transported (even if by BLS ambulance). Issues remain that this could be looked at very carefully by watchdog agencies and that any attempt for abuse (billing/over charging). Gary E. Wiemokly, M.P.H., EMT-P, R.N. EMS Section Chief Connecticut Department of Public Health 410 Capitol Avenue, MS#12 EMS Hartford, CT 06134-0308 Tele: (860) 509-7975 Fax: (860) 509-7987 Email: gary.wiemokly@po.state.ct.us NASEMSD Survey Responses AL State AK Am. Samoa AZ AR CA CO CT DE DC FL GA Guam HI ID IL
IN Mike Garvey The providers that I have talked to in Indiana have indicated they can bill the ALS level if in good faith they were sent and performed the paramedic level assessment. IA KS KY LA Steve Erwin Per your request. I sent your question to Jamie pafford in Arkansas who is considered on of the best authorities on Medicare billing procedures. In the Medicare billing structure there is a provision for "ALS Assessment." The service is allowed to bill ALS-1 when the paramedic is dispatched to the scene (in CT via EMD Protocols) in good faith believing ALS is required, if the patient does NOT require paramedic (ALS) level care and BLS cares for the patient and transports, can the paramedic service bill the ALS assessment? ALS TRUCK RESPONDED, ALS DID NOT TRANSPORT, BUT DID AN ASSESSMENT? IF ALS DID NOT TRANSPORT, THEY CANNOT BILL UNLESS IN PENNSYLVANIA AND IT IS A ME PARAMEDIC INTERCEPT...WITH SOME OTHER GUIDELINES. THE PROPER WAY TO BILL ALS 1 IS, IT HAS TO BE AN EMERGENCY AND THE MEDIC MUST DO AN ALS ASSESSMENT ON THE PATIENT AND SHOULD DOCUMENT SUCH. A BLS UNIT COULD NOT BILL FOR AN ALS ASSESSMENT. MD MA
MI Bob Bass responded I was a member of the CMS negotiated rulemaking committee that developed the current fee schedule. There is a provision for billing ALS when an ALS assessment is required. That is defined as when the call information indicates that the an ALS assessment is required... even if after the assessment it is determined that the patient can be transported at the BLS level. The bottom line is that there must be transported... but if that is at the BLS level, you can still bill at the ALS1 since an ALS assessment was required to make that determination. MN I don't know how the various intermediaries are addressing this issue. It seems to me that if you are using one of the national EMD programs or regionally or state approved dispatch protocols, you have a good case to make. One word of caution is that it should not be abused... like sending ALS to all calls to do an ALS assessment. I would worry that this would raise a red flag. MS MO MT NE NV NH NJ NM NY NC ND MP OH
OK Shawn Rogers I checked with our state EMS billing maven: she says there is a lot of confusion on this. She says you need to have a reason to have an ALS assessment. If you have no signs and symptoms to justify an ALS assement, then you won't be able to justify an ALS assessment charge. OR If on the other hand you arrive on the the scene and discover a need for an ALS assessment (eg, leg injury turns out to have resulted from an unexplained syncopal episode), you can charge for it even if the original call description did not indicate it. Using the new medicare condition codes should help explain the need: we're seeing real improvement in the accuracy of the reimbursement and a decrease in denials since they went into effect. PA PR RI SC SD TN TX UT
VT Dan Manz Interesting scenario and I am not sure we have that exact situation in VT. I would be very cautious about allowing this given what I know about the fee schedule and the ALS assessment. The logic behind the ALS assessment was that a pt with chest pain could reasonably be assumed to require ALS, so the responding agency commits ALS resources to the call but upon arrival at the scene and after assessment, it turns out that ALS is not required. Medicare bought the idea that they should still pay the ALS rate since it was reasonable to commit the ALS resources based on the initial report of the problem. The twist that you provide and I am not sure that Medicare ever considered is an ALS assessment where it is determined that the pt has a BLS problem and now ALS hands off to a BLS crew only. The question really is, does an ALS assessment count if it is only an initial assessment or does it need to include an ongoing assessment. From a purely conservative perspective, it would be much easier to justify the claim as legitimate for ALS if the patient had access to ALS throughout the prehospital encounter. Medicare might reasonably ask the question about why they should pay an ALS rate on a pt. judged to only need BLS who then turned sour enroute and ALS was not available. VI I'll try to make some casual inquiries among my smart billing colleagues who may tell me that I am all wet and this assessment without accompanying transport happens all the time! VA Gary Brown The Virginia Office of EMS does not have any authority, jurisdiction or involvement in the state's medicare billing structure. Sorry I can't help you. WA WV WI WY Totals nasemsd:svy.wp1