First some background. I am with a small volunteer ambulance service in rural Utah. Our local hospital is a CAH operated by a large regional healthcare organization (hospitals, clinics, home health, insurance, etc.). We transfer about 150 patients a year from the CAH to metropolitan trauma centers/specialty hospitals. Of those 150 transports, a majority of the time the CAH sends a RN and sometimes a RRT. Because most patients are transported to hospitals within the system they remain on inpatient status.
I am in no way a CMS scholar. The more I read, the less I understand. Currently, our ambulance service bills the patient for the transport under part B. I read somewhere that an inpatient cannot be billed separately and the cost must be bundled with payment under part A. Obviously these two things are contradictory.
So on to my questions for those of you out there who have a lot more knowledge on the subject than I do:
1. Should our ambulance service be billing the hospital for the interfacility transfers or continue billing the patient under part B?
2. Is your answer to question 1 the same for other payers other than Medicare?
3. If the hospital is billed can the bill be negotiated between our service and the hospital? I ask this question because when we transport patients under this healthcare system's home health, they call ahead of time and set up payment prior to the actual service.
4. If others are billing hospitals for IFT's, does the hospital actually pay what is billed?
The way I see it, if we should be billing the hospital and not the patient our revenue will more than double IF the hospital actually pays what is billed. Under this scenario, our service could actually afford to pay for a few paramedics to provide ALS (we currently are licensed at the AEMT level). We could also reimburse our volunteers for their time being on-call (we currently reimburse them for going on a call only). Also, if we are able to afford paramedics, there are other ambulance services in our area that could utilize them as an intercept service which I think would only improve the quality of care provided in our rural area (as long as they are quality paramedics of course).
Depends, is the best answer I can give. Depends on the set up of the larger health system, depends on if the CAH actually does discharge for the transfer, which again depends on the set up of the larger health system. You are correct that there are times when a patient is moved from one campus to another within the same system, the hospital pays the cost of the transport, but this is not always true.
My advise would be talk to a CMS knowledgeable EMS knowledgeable lawyer. The flip side of this coin, if you are billing CMS inappropriately and they find out, you will have to re-pay + possible penalties. First, I would talk to the CAH administration and see if they are a fully owned entity of the larger system, what the organizational structure is (there are times when the affiliation doesn't reach the level of 'same system' legally). THEN, call the lawyer.
In the end the patient will always have to eat the bill. The hospitals or healthcare facilities will not pay those bills.