Medicare Compliance & Reimbursement

As health care fraud enforcement heats up for ambulance suppliers - especially at the state level - making sure you play by the rules is more important than ever. And the HHS Office of Inspector General made the game book a little clearer March 24, with the release of its compliance program guidance for ambulance suppliers.

The ambulance CPG gives a high profile to medical necessity, noting that "medically unnecessary transports have formed the basis for a number of Medicare and Medicaid fraud cases." Within the overall rubric of medical necessity, the OIG says ambulance suppliers should take special pains to ensure that claims for non-emergency transports are legitimate and well-documented, and that physician certification statements are secured where appropriate.

Inadequate documentation has also been a big stumbling block for suppliers, and in its guidance the OIG stresses that, when documenting a service, ambulance personnel "should not make assumptions or inferences to compensate for a lack of information or contradictory information on a trip sheet, ACR, or other medical source documents."

The CPG outlines kickback concerns at considerable length, identifying arrangements involving emergency medical services - such as municipal contracts and ambulance restocking deals - and arrangements with other responders, hospitals, nursing facilities and patients as deals that could raise kickback specters.

Lesson Learned: Compliance programs are by this point a fact of doing business with Medicare and Medicaid, and with the issuance of formal guidance from the OIG, ambulance suppliers have no excuse for not getting a program in place.