This blog post is part of a series that addresses ambulance billing best practices. Our ambulance billing blog series highlights tips and insights to help you improve ambulance billing efficiency, lower ambulance claim rejections, and get reimbursed faster.
The challenge is real because you have to rely on the facility requesting the non-emergency ambulance services to make sure the PCS is filled out properly by the right person and on-time. It helps when your EMS Dispatch/Intake staff have a good relationship with the facilities and can collect the PCS before the crew leaves the station, but even then, there can be obstacles when individuals coordinating the non-emergency ambulance transport don’t have a clear understanding of why or when a PCS is required.
Furthermore, when crews are relied on to collect the PCS at the time of transport, they often spend precious time tracking it down or trying to get valid signatures, causing transport delays and creating call backlogs.
This blog post breaks down the Physician Certification Statement do’s and don’ts that are key to successful, compliant EMS reimbursement of medically necessary non-emergency ambulance services.
A Physician Certification Statement (PCS) is a written order certifying the medical necessity of non-emergency ambulance transports. Centers for Medicare and Medicaid Services (CMS) requires a PCS for both scheduled and unscheduled non-emergency ambulance transports for patients under the direct care of a physician.
As defined by CMS, there are four non-emergency ambulance transport scenarios:
When a PCS cannot be obtained in accordance with CFR Section 410.40(d)(3) (iv)">42 CFR Section 410.40(d)(3)(iv), a provider/supplier may send a letter via USPS Certified Mail with a return receipt proof of mailing or other similar commercial service demonstrating delivery of the letter as evidence of the attempt to obtain the PCS.
The facility’s ordering physician is requesting the non-emergency ambulance transport, which means the facility is responsible for completing the PCS. However, the EMS agency should furnish the facility with a PCS template form that meets the CMS guidelines for non-emergency ambulance transport reimbursement. Ultimately, it is the ambulance provider’s responsibility to make sure the proper documentation is obtained and why it is extremely important to try and collect what is needed during call intake/dispatch.
All parties (facility staff, crew, EMS billers) need to understand who can/cannot sign the Physician Certification Statement, which is dependent on the type of non-emergency ambulance transport:
Some key items that CMS outreach is trying to address regarding PCS signatures and credentials include:
In all cases, the provider or supplier must keep appropriate documentation on file and, upon request, present it to the Medicare contractor. The presence of the signed certification statement or signed return receipt does not alone demonstrate that the ambulance transport was medically necessary. All other program criteria, including a PCR, must be met in order for payment to be made.
The collective documentation for a non-emergency ambulance transport should “paint a picture” of medical necessity. And, just as important, the documentation should not contradict each other.
The PCS should be individualized for each patient and reflect the patient’s condition at the time of transport. Even if you are dealing with a repetitive patient that is always in the same condition, you cannot copy previous PCSs then sign and date it like it’s new.
All new staff members should be trained on PCS guidelines and processes, and refresher training should occur annually.
Some state Medicare contractors have adopted the Prior Authorization model for scheduled, repetitive non-emergency ambulance transports. It’s important to know your specific state guidelines. The following state Medicare contractors follow the Prior Authorization requirements: Delaware, District of Columbia, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina, Virginia, West Virginia. More information related to the CMS Prior Authorization Model can be found here.
AIM’s EMS Billing Service has created a PCS cheat sheet that many EMS dispatchers, crew members, and EMS billers have found helpful and we are happy to share it with you. Just email us at sales@aim-system.com, and we’ll send you an electronic version.
If you have questions for us on non-emergency ambulance billing — or any other type of ambulance transport billing — don’t hesitate to give us a call at 1-800-726-4690. We are here to help!
More non-emergency ambulance services resources:
Other articles in this Ambulance Billing Best Practices blog series: