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Clarification of Ambulance Transports


To:        NHPCO Membership
From:   NHPCO Regulatory Team
Re:        February 26, 2010

Clarification of ambulance transports on the day of hospice admission

Summary at a Glance:

In addition to CR 6778 proving clarification about payment of ambulance transports on the effective date of hospice election, CMS has also updated Medicare Benefit Policy Manual (CMS Pub. 100-02) with additional information.  CMS has defined the circumstances when the hospice provider is responsible for the cost of ambulance transport.

  • Hospice responsible:  Ambulance transports of a hospice patient, which are related to the terminal diagnosis and which occur after the effective date of election, are the responsibility of the hospice.
  • Hospice not responsible:  Ambulance transports which occur on the effective date of the hospice election (i.e., the date of admission), but prior to the initial assessment and prior to the plan of care’s development. (Per the S & C 09-19, Advance Copy-Hospice Program Interpretive Guidance Version 1.1,the initial assessment must be conducted in the location where hospice services will be provided, and the plan of care is developed from that initial assessment and from the comprehensive assessment.)

Implementation date:  For claims submitted on or after July 6, 2010

CMS has updated the Medicare Claims Processing Manual, Chapter 11 - Processing Hospice Claims with information on who is responsible for the payment of an ambulance claim.   The manual change is as follows:

40.1.9 - Other Items and Services

(Rev. 121; Issued: 02-05-10; Effective Date: For claims submitted on or after July 6, 2010; Implementation Date: 07-06-10)

The hospice Interpretive Guidelines for 42 CFR 418.54(a), published via a Survey and Certification letter (S & C 09-19, Advance Copy-Hospice Program Interpretive Guidance Version 1.1), require that the initial assessment be conducted in the location where hospice services will be provided. The plan of care is developed from that initial assessment and from the comprehensive assessment. Ambulance transports which occur on the effective date of the hospice election (i.e., the date of admission), would occur prior to the initial assessment and therefore prior to the plan of care’s development. As such, these transports are not the responsibility of the hospice. Medicare will pay for ambulance transports of hospice patients which occur on the effective date of hospice election through the ambulance benefit rather than through the hospice benefit. Ambulance transports of a hospice patient, which are related to the terminal diagnosis and which occur after the effective date of election, are the responsibility of the hospice.

EXAMPLE:

A hospice determines that a patient’s condition has worsened and has become medically unstable. An inpatient stay will be necessary for proper palliation and management of the condition. The hospice adds this inpatient stay to the plan of care and decides that, due to the patient’s fragile condition, the patient will need to be transported to the hospital by ambulance. In this case, the ambulance service becomes a covered hospice service.

NHPCO comments:

NHPCO received multiple questions from hospice providers in the past year about coverage for ambulance transport and we took your concerns to CMS.  We are very pleased that CMS has clarified in writing the circumstances of when a hospice provider is responsible for transport coverage.

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