All Ambulance Services Urged to Submit
Comments to CMS Regarding the Final Rule
on Patient Signatures by December 31st
Deadline
As we have reported, a new Final Rule is
scheduled to go into effect on January
1, 2008 regarding patient signature
requirements for Medicare claims. These
new regulations will impose substantial
burdens on all ambulance providers,
whether public, private or non-profit.
PWW has, from the initial publication of
these new regulations, encouraged all
ambulance services to comment and make
their opinions and concerns known to
CMS. We remind everyone that the comment
period set forth in the Federal Register
notice expires on December 31, 2007, so
time is of the essence to make your
concerns known to CMS. Tell them about
the burdens this final rule will place
on your organization and its personnel
and to give them examples of the
confusion that it has generated. We have
received hundreds of questions about the
new rule that have yet to be addressed
by CMS. CMS has not even provided
instructions to its Medicare contractors
as to how the regulations should be
applied.
We believe that CMS should withdraw this
regulation until the impact of any
change from the current regulations can
be fully evaluated. We encourage CMS to
review the many questions that have
arisen since publication of the final
regulations before re-publishing any
changes to the current signature
regulations. We encourage you to make
those two points in your comments to
CMS.
The following are detailed instructions
from the Federal Register on the various
options for submitting comments:
1. Electronically. You may submit
electronic comments on specific issues
in this regulation to
http://www.cms.hhs.gov/eRulemaking
.
Click on the link ''Submit electronic
comments on CMS regulations with an open
comment period.'' (Attachments should be in
Microsoft Word, WordPerfect, or Excel;
however, we prefer Microsoft Word.)
2. By mail. You may mail written comments
(one original and two copies) to the
following address ONLY: Centers for Medicare
& Medicaid Services, Department of Health
and Human Services, Attention: CMS-1385-FC,
P.O.Box 8020, Baltimore, MD 21244-8020.
Please allow sufficient time for mailed
comments to be received before the close of
the comment period.
3. By express or overnight mail. You may
send written comments (one original and two
copies) to the following address ONLY:
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1385-FC, Mail Stop C4-26-05,
7500 Security Boulevard, Baltimore, MD
21244-1850.
4. By hand or courier. If you prefer, you
may deliver (by hand or courier) your
written comments (one original and two
copies) before the close of the comment
period to one of the following addresses. If
you intend to deliver your comments to the
Baltimore address, please call telephone
number (410) 786-7197 in advance to schedule
your arrival with one of our staff members.
Room 445-G, Hubert H. Humphrey (HHH)
Building, 200 Independence Avenue, SW.,
Washington, DC 20201; or 7500 Security
Boulevard, Baltimore, MD 21244-1850.
(Because access to the interior of the HHH
Building is not readily available to persons
without Federal Government identification,
commenters are encouraged to leave their
comments in the CMS drop slots located in
the main lobby of the building. A stamp-in
clock is available for persons wishing to
retain a proof of filing by stamping in and
retaining an extra copy of the comments
being filed.)
We have also been asked by the American
Ambulance Association to make available to
our e-mail subscribers a copy of a comment
"form letter" that they have developed for
ambulance services to use for this purpose.
The AAA's model form letter is available on
our website.
CLICK HERE to read PWW's summary of this
Final Rule, as well as to download a copy of
the actual Final Rule, and to download a
copy of AAA's model form letter for
submitting comments.
PWW is also making available an audio CD
of its recent National EMS Law Audio
Conference on "The New Medicare
Signature Rules."
CLICK HERE for to order this
recording, which comes complete with
complete program handout materials as
well as sample signature forms for your
organization's compliance with this rule
by the January 1st deadline.
