CLICK HERE to download PWW's free sample Patient Signature Forms to help you comply with these new regulations!

Signature requirements for filing Medicare claims in instances where the beneficiary is unable to sign will change significantly as of January 1, 2008.  Under the provisions of a Final Rule published by the Centers for Medicare and Medicaid Services (CMS) in the November 27, 2007 Federal Register, in those instances where a beneficiary is physically or mentally unable to sign an Assignment of Benefits (AOB) form, ambulance suppliers will be required either to obtain the signature of an acceptable surrogate, or, with respect to emergency ambulance services, meet stringent new documentation requirements before submitting the claim to Medicare.  These rules will substantially affect 911 emergency ambulance providers in particular. These new requirements include three types of documentation:

(A) A signed, contemporaneous statement from an employee of the ambulance service, present during the transport, documenting that the patient was physically or mentally incapable of signing and that no other authorized signers were available or willing to sign; and

(B) Documentation with the date and time the patient was transported, and the name and location of the receiving facility; and

(C) Either of the following:

(1) A signed, contemporaneous statement from a representative of the receiving facility, which documents the name of the patient and the date and time the patient was received by that facility; or

(2) A "secondary form of verification," obtained at a later date, but prior to submitting the claim to Medicare, which may include:

(i) A hospital representative signature on the ambulance trip report;

(ii) The hospital registration/admissions sheet;

(iii) The patient medical record; or

(iv) "Other internal hospital records."

These rules become effective on January 1, 2008.  

The Final Rule makes it clear that this alternative applies only to emergency ambulance services; in other words, CMS is implying that ambulance services can no longer rely on the "patient unable to sign" rule for non-emeregncy claims; a signature of the beneficiary or some authorized signer must be obtained prior to submitting the claim to Medicare for non-emergency ambulance claims.

In short, this new Rinal Rule is going to substantially change the way ambulance services do business, and it will significantly increase the need for complete and thorough documentation - including signatures - at the time ambulance services are rendered.  If no signature is obtained at the time of service, ambulance services should expect their claim filing and cash flow to be significantly delayed. 

We strongly encourage all ambulance services to submit comments to CMS, before the December 31, 2007 comment deadline, regarding this new rule, which, in our view, will place many burdens on ambulance services of all type - public, private and non-profit, emergency and non-emergency alike, and has many unintended consequences that will negatively affect the industry.  CLICK HERE to download a sample form letter for submitting comments to CMS, prepared by the American Ambulance Association and made available here by their request (Word format, 3 pages).

CLICK HERE TO DOWNLOAD THE FINAL RULE as published in the November 27, 2007 Federal Register (NOTE: this file contains the ambulance excerpts only; PDF format, 20 pages).