CMS Released New Non-Emergency Documentation Guidance

For the First Time Ever, CMS Published EMS Documentation Templates

Last Thursday, CMS hosted a last-minute Ambulance Open Door Forum to discuss the new clinical templates and suggested clinical data elements (CDEs) to support the need for Non-Emergency Ambulance Transportation.  Here's what you need to know:

What They Are 
Draft templates and CDEs for:

  • Physician Certification Statement
  • Progress Note
  • Prior Authorization Request

The CDEs are to be used by IT vendors in creating or enhancing electronic platforms.  The templates are for providers to use in printed or downloaded form.    

Why They Were Created
According to recent reports, the improper payment rate for non-emergency ambulance transportation was 15.5% or $687 million.  And 57.3% of those improper payments were due to incomplete documentation.  CMS believes these templates will be helpful to ambulance services when prior authorization is required as well as when additional documentation is requested by MACs, when an agency is audited or subject to pre-pay review.

How Does It Affect You?
While the use of these documents is not mandatory, it is likely that this guidance will become the standard MACs and other auditors expect when reviewing your documentation so it's crucial all EMS agencies review and understand these forms.   These templates are currently drafts, but are expected to be finalized in the next few months. CMS is requesting feedback and suggestions be sent to clinicaltemplates@cms.hhs.gov.

What PWW is Doing
Our attorneys and consultants are reviewing the templates and CDEs and preparing to provide suggestions to CMS.  We will be closely monitoring future drafts and other communications from CMS regarding these templates and CDEs and will provide in-depth coverage of these documents and what it means for the industry and your agency at abc360.  Registration is now open for all four 2018 - 2019 locations.