MEDICAL TRANSPORT PERSONNEL SCOPE: All AMR HoldCo, Inc. and its subsidiaries (the Company ) colleagues. For purposes of this policy, all references to colleague or colleagues include temporary, part-time and full-time employees, independent contractors, clinicians, officers and directors. PURPOSE: To provide guidance to its Medical Transport Personnel colleagues for American Medical Response, Inc. and its subsidiaries (collectively, the Company ). POLICY: I. INTRODUCTION 1. Medical Transport Personnel MTP/Field Providers play a vital role in AMR's operational success and in AMR's ability to comply with the complex health care laws and regulations. While Intake Personnel are the voice of AMR, MTP/Field Providers are the arms and legs of AMR, because they directly interact with patients. Because providing and documenting patient care is the center of your duties, it is very important for you to be courteous, customer friendly, and provide exceptional patient care at all times. 2. AMR has designed this Policy (the "Policy") to help you better understand the importance of your job tasks and how they relate to AMR s compliance to these health care laws and regulations. 3. This Policy is in addition to any existing MTP/Field Provider policy, protocols, or job descriptions. II. GENERAL DUTIES FOR CREW MEMBERS 1. Ambulance MTP/Field Providers are the personnel who are responsible for transporting the patient and are generally paramedics or emergency medical technicians who must be licensed or certified according to state laws. Page 1 of 6
2. MTP/Field Providers must notify local management if there is a lapse, for any reason, of any of the required licenses and/or certifications required based on local and state regulations. Failure to immediately notify will result in disciplinary actions up to and including termination. 3. MTP/Field Providers have an ethical obligation to treat each patient consistently and adequately regardless of patient's race, color, religion, sexual orientation, or potential billing status. City, county, state, and company protocols have been developed to help MTP/Field Providers provide the required level of patient care. Patient care should be in accordance with Local medical protocols as established and/or approved by the local Medical Director. 4. During the transport of a patient, or as soon thereafter as possible, MTP/Field Providers must complete a Patient Care Report ("PCR"). The PCR is confirmation that the transport took place and describes the need for the ambulance and services provided and allows AMR to seek reimbursement from the patient s health insurance, when appropriate. Each PCR should provide a thorough and accurate description of the patient encounter. III. PROCESSING THE PATIENT CARE REPORT 1. PCRs should contain information that provides patient demographics along with a thorough and accurate description of the entire patient encounter. Documentation requirements should be in accordance with local Standard Operating Procedures and contain the following recommended items. Please note these are recommended items but in some rare instances, some of the information may not be available to the MTP/Field Personnel (i.e. Dispatch code and information regarding the patient s condition at the time of dispatch). 1. Origin and Destination; 2. Dispatch Information; 3. Patient Demographics: 4. Reason for Transfer; 5. Physical Findings; 6. Chief complaint at time of transport; 7. Past Medical History; 8. Narrative - Thorough description of the patient encounter; 9. Vital signs (2 sets); 10. Treatment rendered (e.g. oxygen, EKG, drugs); Page 2 of 6
11. Loaded miles using trip counter/mapping mileage (Medicare requires mileage be documented to the nearest tenth of a mile; 12. Field Provider signatures (Attendant and Driver); and 13. Patient signature or alternate signature/documentation 2. There are often other forms of medical documentation that Field Providers receive, such as PCS forms, hospital and nursing home face sheets and discharge summaries. All additional information regarding the patient s medical condition must be attached to the PCR before it is sent to the Billing Center. 3. The PCR should be completed by the end of the shift during which the transport occurred, must contain accurate information, and must be received by the Billing Office within the Division-specified number of days from when the service was provided. Addendums must be completed within the Carrier specific timeframes, as applicable and must be completed by the applicable crew member IV. DOCUMENTATION A. Accurate and complete documentation of the entire patient encounter is extremely important to comply with health care rules and regulations. A PCR should contain the items listed in Section III. 1.., along with the following: 1. Describe the patient's medical condition at the time of transport and the reason for transport; 2. Describe how the patient was found (e.g. in bed, in a wheelchair, standing, unconscious); 3. Describe how the patient got to the stretcher and ambulance (e.g. walked with assistance, lifted by draw sheet); 4. Document the patient s physical and mental assessment and other pertinent finds; and 5. Explain why the patient could or could not go by other means (e.g. comatose, severe lower extremity contractures, why patient could not self-regulate oxygen during transport, required restraints, etc.). B. Use only acceptable abbreviations in completing the PCR. Page 3 of 6
C. Paint an accurate and legible picture of the entire patient encounter. V. PATIENT SIGNATURES MTP/Field Providers are responsible for obtaining the patient s signature on the PCR Master Signature Statement, as specified in AMR Compliance Policy on Obtaining Patient Signatures, Policy No. 40300. VI. ADVANCE BENEFICIARY NOTICE OF NONCOVERAGE An Advance Beneficiary Notice of Noncoverage (ABN) notifies patients that AMR believes the service provided may not be fully covered by Medicare because it is not reasonable and necessary under Section 1862(a)(1) of the Social Security Act. For more information related to ABNs, see AMR Compliance Policy on Obtaining Patient Signatures, Policy No. 40300. VII. PHYSICIAN CERTIFICATION STATEMENT AMR must attempt to obtain Physicians Certification Statements (PCS) before it can bill Medicare for scheduled repetitive non-emergency transports and for other scheduled and unscheduled non-emergency ambulance transports of patients under the direct care of a physician. The specific requirements for a PCS depend on whether the transport is a repetitive transport or a non-repetitive transport. MTP/Field Provider must understand these requirements so that, when appropriate, they can explain them to requesting facilities and assist in obtaining PCS forms required for specific patients. Local Standard Operating Procedures may prescribe specific procedures for addressing PCS issues, so long as such procedures are approved by the Ethics & Compliance Department. A. Dispatch Personnel may instruct MTP/Field Providers regarding the need to obtain a PCS at the time of transport, in which case the MTP/Field Provider should briefly review the form to make sure it has all the required information and is signed by an appropriate person, as indicated above. B. AMR Personnel can complete the demographic portion of the PCS form but cannot enter any of the information in the medical necessity portion of the document. No modifications to the PCS form can be made after it has been signed and dated by an authorized signor. Page 4 of 6
1. Scheduled Repetitive Non-Emergency Transports: AMR is required to obtain a PCS dated no earlier than sixty days prior to the date of service in order to bill Medicare for repetitive transports. The PCS must be on file, or must be obtained, prior to the transport. Repetitive transports are those transports that occur three or more times during a ten-day period or once per week for at least 3 weeks for treatment of the same condition, such as dialysis and respiratory therapy. This would exclude transports for follow-up visits relating to a single and non-continuing incident. The PCS for a repetitive transport must be signed and dated by a physician; 2. Non-Emergency Services for a Facility Patient under the Care of a Physician: For these patients, AMR must attempt to obtain a PCS within 48 hours after the transport whenever possible. If it is not possible to obtain a PCS signed by the physician, a signed and dated certification can be obtained from a P.A., N.P., clinical nurse specialist, R.N. or discharge planner who is employed by the hospital/facility where the beneficiary is being treated and from which the beneficiary is transported, or employed by the beneficiary s attending physician, and who has personal knowledge of the beneficiary s condition at the time the transport is ordered or performed. VIII. TRAINING OF MEDICAL TRANSPORT PERSONNEL A. Required compliance training for MTP/Field Provider will be provided by AMR s Ethics and Compliance Department and/or designated employees. Training should take place upon initial employment and annually thereafter. B. Ongoing training for MTP/Field Providers, according to Divisional policy, shall include specialized training regarding PCR documentation. AMR Operations management will work jointly with the Ethics & Compliance Department to develop and present the specialized training. IX. QUALITY IMPROVEMENT A. Each AMR Business Unit will be responsible to develop, implement, and maintain ongoing quality improvement procedures to monitor the services provided by field providers. B. The results of quality improvement reviews shall be retained in accordance with the Page 5 of 6
AMR Compliance Policy on Records Management, Policy No. 10600. C. The quality improvement process shall include procedures to provide timely corrective feedback and training to employees, as necessary. X. CORRECTIVE ACTION A. This Policy for MTP/Field Provider establishes the general policies and procedures with which all MTP/Field Providers must comply as a condition of employment with AMR. This Policy is designed to ensure that each employee s performance conforms to the highest ethical standards and is in accordance with all applicable laws, rules and regulations. Any doubts or questions whatsoever as to the propriety of a particular situation, whether or not the situation is described within this Policy, should be addressed either to your immediate supervisor or to one of AMR s Ethics & Compliance Personnel. B. Any MTP/Field Provider violating any provision of this Policy will be subject to disciplinary action, up to and including discharge from employment. In addition, promotion of and adherence to this Policy and to the Corporate Ethics & Compliance Program will be one criteria used in evaluating the performance of supervisors, managers, directors, and officers. Page 6 of 6