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2020 Changes to Physician Certification Statements

Published Tuesday, January 07, 2020

The Centers for Medicare and Medicaid Services (CMS) just released a Final Rule outlining changes to the Physician Certification Statement (PCS) requirements and the Ambulance Data Collection System. Both initiatives go into effect on January 1, 2020, so it is critical that ambulance services begin preparing now by updating written and electronic PCS forms and ensuring they are capable of tracking and reporting data that CMS will be requesting over the next four years.

Distinction Between Types of Certification Statements
Beginning January 1, 2020, there will be a distinction between a Physician Certification Statement and a Non-Physician Certification Statement. Here’s how it works.

A Physician Certification Statement is defined as a statement signed by the beneficiary’s attending physician. A Non-Physician Certification Statement is defined as a statement signed by an individual other than the beneficiary’s attending physician.

To accomplish this, CMS added a new paragraph (a) to the regulations at 42 CFR § 410.40 to define a PCS and a non-physician certification statement. As a result, all of the subsequent paragraphs now change. Most significantly, paragraph (d) “Medical necessity requirements” will be redesignated as paragraph (e) effective January 1, 2020.

In addition, CMS is removing all references to a “physician’s order.” The current regulation refers to a “written order from the beneficiary’s attending physician” and states that a “physician’s order must be dated no earlier than 60 days before the date the service.” CMS is removing the references to a physician’s order and beginning January 1, 2020, the regulation will only refer to a “physician certification statement”.

Page Wolfberg and Worth, a law firm specializing in the ambulance transport industry, believes that the simplest way to account for these revisions is to change the title of PCS forms by removing the word “Physician” and simply calling the form a “Medical Necessity Certification Statement.” Whether the form qualifies as a Physician or Non-Physician Certification Statement will simply depend upon who signs it.

Additional Non-Physician PCS Signers for Transports that are Unscheduled or Scheduled on a Non-Repetitive Basis
Beginning January 1, 2020, the following individuals are authorized to sign for non-repetitive and unscheduled transports:

  • Licensed practical nurse (LPN)
  • Social workers
  • Case managers
As with the other non-physician staff currently permitted to sign non-repetitive, unscheduled PCS forms, LPNs, social workers and case managers need to be employed by the beneficiary’s attending physician or the hospital or facility where the beneficiary is being treated and from which the beneficiary is transported. The must also have personal knowledge of the beneficiary’s condition at the time the ambulance transport is ordered or the service is furnished.

Ambulance services who use PCS forms (or an electronic equivalent) will need to update them to ensure compliance with these three new signers by January 1, 2020.

Important Note: The new rules does not change the PCS requirements for scheduled, repetitive transports.  
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