Physician Certification Statements (PCS) are written authorizations ambulance suppliers must obtain to verify the medical necessity of an ambulance transportation ordered by a provider/facility. If your agency transports non-emergency patients from one facility to another, you are likely all too familiar with PCS forms and their stringent requirements.
It’s not fair, is it? You, as an ambulance provider, must verify that a completed, valid PCS is done by the facility; otherwise, you cannot bill Medicare for the transport. Yet, some providers or facilities fail to ensure the PCS is complete at the time of transport. To help you overcome this hurdle, below are some tips for your agency to follow that may help guarantee all sections of the PCS are completed prior to departure and the requirements for billing Medicare are met.
- Always Obtain a PCS
A PCS is only required for Medicare beneficiaries. However, insurance information may not be readily available by the facility at the time of transport. How, then, do you know when to get a PCS? The answer is always.
Regardless of whether insurance information has been obtained, make it best practice to always obtain a PCS if you are transporting a patient from one facility to another. For example, there are cases where a patient might be self-pay at the time of transport and is later identified as having Medicare coverage. To be as diligent as possible for every encounter, it is best to obtain a PCS for every non-emergency interfacility transport.
- Confirm Completion Before Departure
Confirm completion of the PCS prior to departing the facility. Page, Wolfberg, & Wirth (PWW) provides a free, downloadable PCS form on their website to use as an example when creating your agency’s PCS form. This form covers all aspects of what needs to be documented prior to transporting the patient and is available in Word format, making it readily customizable for your agency.
Use of this form makes it easy to identify if a provider/facility left any section incomplete so that the medic, when necessary, can approach the facility requesting completion prior to transport. A few common items on the PCS that are required and may need a medic’s verification prior to departure include:
- A legible signature and printed name for the authorized PCS signer.
- Credentials after the authorized PCS signer’s name. The indication of “Dr.” prior to the signer’s name is not acceptable.
- An authorized signer. Medicare states the authorized signer must have personal knowledge of the beneficiary’s condition at the time the ambulance transport is ordered. Providers authorized to sign are as follows:
- Physician Assistant
- Nurse Practitioner
- Clinical Nurse Specialist
- Registered Nurse
- Discharge Planner
- A reason for transport. The PCS should confirm the medical necessity behind the transport by providing the reason for the transport and the condition of the patient that prevents him/her being transported by any other means. The PCS on the PWW website provides detailed selections in Section II for this documentation piece by confirming if the patient is bed-confined and, if not, identifying why the patient cannot be safely transported by another party (reasons may include contractures, a comatose state and so forth) or detailing the patient’s condition in the description section (item #1).
- Provide Medical Necessity
The run record must reflect medical necessity, coinciding with the PCS. The PCS alone is not enough to verify medical necessity when billing Medicare. Instead, the patient care report and PCS should reflect the same documentation and necessity.
Below are key items medics must remember to document in regard to medical necessity:
- Services being provided by the medic during transport that coincide with the PCS (continuous oxygen, IV maintenance and so forth).
- The patient’s condition requiring ambulance transport. For example, “patient is bed confined due to paralysis of upper and lower extremities.”
- Specific services not available at the sending facility. For example, cardiologist, neurologist, gastroenterologist, and so forth all provide the specific service not available at the sending facility and confirms the reason the patient needs transport out of the current facility.
In the documentation itself, a medic could chart “Patient is being transported from Hospital A to Hospital B for Cardiologist, as this service is not available at Hospital A.” In the event of an audit, CMS will most likely look to see if the services are available at the sending facility. When it is documented that “x services are not available at sending facility,” this leaves no interpretation of what service the sending facility was unable to provide for the patient.
In addition to fine-tuning your agency’s process, one simple measure to take in helping improve PCR completions would be to communicate with your frequented facilities to ensure they have the proper understanding of your agency’s EMS billing needs. Taking this proactive approach to build that relationship with these facilities will save you a lot of time and effort in the future.
For additional online training regarding this topic, Intermedix offers free web-based training available 24/7 at https://learning.intermedix.com. Please reach out to your Client Relations Manager for additional information in accessing this portal.