On September 29, 2015, the U.S. DHHS Inspector General’s Office (the “OIG”) released a report (OEI-09-12-00351) entitled “Inappropriate Payments and Questionable Billing for Medicare Part B Ambulance Transports.”

The report is significant and discusses the issues the OIG has been concerned with relating to Medicare Part B ambulance transports. OIG notes that in 2012 Medicare Part B payments for ambulance transports were almost double the amount it paid in 2003. OIG has historically been concerned about fraud involving ambulance transports. CMS continues to impose a moratorium on new ambulance providers in certain geographic areas. Importantly, OIG noted that the majority of its findings in the report were limited to four metropolitan areas, Philadelphia, PA, Los Angeles, CA, New York, NY and Houston, TX.

The OIG study analyzed claims data for 7.3 million ambulance transports during the first half of 2012. It examined aspects of the transports including, but not limited to, transport destinations, transport levels, distance of urban transports, other Medicare services that beneficiaries received, and the geographic locations where the beneficiaries who received transports resided.

According to the OIG, it identified a significant number of improper payments and questionable billing. It found $24 million in claims paid in the first half of 2012 did not meet certain program requirements to justify payment. The issues included: (1) transports that were to or from non-covered destinations such as physicians’ offices; (2) transports where beneficiaries did not receive Medicare services at the pick-up or drop-off locations; and (3) unusually high average mileage for transports provided to beneficiaries residing in urban areas.

Based on its findings, the OIG recommends that CMS –

(1) determine whether a temporary moratorium on ambulance supplier enrollment in additional geographic areas is warranted;

(2) require ambulance suppliers to include the National Provider Identifier of the certifying physician on transport claims that require certification;

(3) increase its monitoring of ambulance billing; and

(4) determine the appropriateness of claims billed by ambulance suppliers identified in the report and take appropriate action.

A copy of the report can be found here – http://oig.hhs.gov/oei/reports/oei-09-12-00351.pdf

The report may signal a new focus on ambulance billing enforcement, particularly in the geographic areas mentioned. Additionally, it would not be surprising if CMS expanded its enrollment moratoria soon in those areas.