Repetitive, Scheduled Non-Emergent Ambulance Transport FAQs

The following questions and answers were taken from emails, phone calls and Q&A sessions derived from webinars and phone calls with The Centers for Medicare and Medicaid Services (CMS) regarding repetitive scheduled non-emergent ambulance transportation (RSNAT) for healthcare common procedure coding system (HCPCS) codes A0426 and A0428.

Q1. What is the earliest date a provider can submit a prior authorization request (PAR)?
A1. Since the signature on the physician certification statement (PCS) cannot be more than 60 days prior to the start date of the prior authorization request (PAR) for repetitive transports, a PAR cannot be submitted prior to 60 days before the anticipated start date of repetitive transports. Ideally, a PAR request should be submitted before beginning repetitive transports.

Q2. How can a supplier know if the beneficiary has an existing unique tracking number (UTN) with another provider?
A2. You can ask the beneficiary or submit a PAR. When submitting a PAR, if the beneficiary has a UTN with another supplier, your decision letter will state that the beneficiary already has a UTN on file with another provider.

Q3. Can a supplier cancel a PAR with another company?
A3. A supplier cannot cancel a PAR/UTN for another provider. If another UTN is needed, the supplier should submit a PAR request with the required documentation.

Q4. What are some things suppliers can do when filing claims to prevent claim rejection or delays in processing?
A4. Suppliers should remember to bill RSNAT claims with the affirmed or non-affirmed UTN attached to the claim. Suppliers should keep in mind that all UTNs begin with the number zero (0). Claims billed with a UTN beginning with the letter “O” cannot be processed, as this is not a valid UTN.

Q5. What happens if the beneficiary has a transport that is not considered a repetitive transport?
A5. Non-repetitive transportation services are not subject to prior authorization. Therefore, you should submit the claim for payment as usual. We could conduct prepayment reviews on any ambulance claims, including claims for non-repetitive transports, for any beneficiary determined to be a recipient of repetitive ambulance services.

Q6. What are the signature requirements for the Physician Certification Statement (PCS)?
A6. The PCS must be signed no sooner than 60 days prior to the start date of the PAR. However, the PCS should be signed before the anticipated start date of the repetitive transports.

Q7. Where can I find the rules and regulations for the RSNAT program?
A7. The best resources for the regulations surrounding repetitive transport can be found in the Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model Operational Guide and the Code of Federal Regulations (CFR) 42 CFR 410.40. These links can be found on The CMS website. You can click the hyperlinks below to access the links.

Q8. What other resources are available to assist providers with rules and regulations?
A8. Other resources can be found on the Noridian and The CMS websites listed below:

Q9. What HCPCS codes can be billed for repetitive, scheduled non-emergent transport (RSNAT)?
A9. The only HCPCS codes that can be billed for repetitive transports are as follows:

  • A0426: Ambulance service, advanced life support, nonemergency transport, level 1 (ALS 1)
  • A0428: Ambulance service, basic life support, nonemergency transport, (BLS)

Any other HCPCS codes billed are invalid and cannot be processed for repetitive transports.

Q10. What medical records can be used to support medical necessity?
A10. While there is no specific rule regarding what types of records are acceptable to support medical necessity, the records submitted MUST be sufficient to support the need for the type of transport requested. As such, it is important to submit medical records that reflect up-to-date and accurate information regarding the beneficiary’s medical conditions requiring ambulance transportation. The medical records submitted are expected to reflect the information provided on the PCS.

Suppliers should make sure the medical documentation:

  • Is clear, concise, and is from the patient’s clinician and not the ambulance supplier
  • Includes patient identifiers and valid signatures
  • Supports the information documented on the PCS
  • Supports the patient’s condition at the requested time of transport
  • Describes the medical necessity of the type and level of transport services by documenting the “what” and “why” of the patient’s condition(s)

Q11. How long are medical records considered timely?
A11. Previously mentioned, it is important to submit medical records that reflect up-to-date and accurate information about the beneficiary’s medical condition. In most cases, medical records dated within the six-months prior to the start of the repetitive transports are considered timely and are sufficient. In some cases, such as for chronic conditions, it is possible that older documentation may be sufficient. However, timeliness of medical records in these cases are evaluated on a case-by-case basis. Overall, it is best practice to provide medical records created within the six-months prior to the expected start date of repetitive transports to support ongoing medical necessity.

Q12. Who may sign the PCS?
A12. For RSNAT, the physician is required to sign and date the PCS. Signature guidelines are outlined in the Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4.

Q13. I have been unsuccessful in obtaining the physician’s signature on the PCS. What are my options?
A13. If you are unable to obtain a physician’s signature on the PCS, you should still submit your claims for payment. While RSNAT claims cannot be paid without a signed PCS, receiving a denial for these claims affords the provider the option to pursue payment of these claims via the appeals process.

 

Last Updated Jun 13 , 2022