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April 24, 2023

Physician Certification Statement Requirements for RSNAT

Repetitive scheduled non-emergent ambulance transport (RSNAT) services require a physician certification statement (PCS) be completed every 60 days. It must also be signed by a physician (MD/DO). Per 42 CFR §410.40:

Physician certification statement means a statement signed and dated by the beneficiary's attending physician which certifies that the medical necessity provisions of paragraph (e)(1)External Website of this section are met.

Special rule for nonemergency, scheduled, repetitive ambulance services.

Medicare covers medically necessary nonemergency, scheduled, repetitive ambulance services if the ambulance provider or supplier, before furnishing the service to the beneficiary, obtains a physician certification statement dated no earlier than 60 days before the date the service is furnished.

A PCS is like a physician’s order. It must be appropriately signed, credentialed, and dated by the physician. It should be signed promptly and in most cases before the service is provided. The physician’s signature on the PCS form signifies he/she has knowledge of the patient. The PCS for repetitive scheduled non-emergent services should only be completed and dated by the patient’s physician.

Unacceptable forms of a PCS for RSNAT services may include the following:

  • Medicaid form marked 365 days or 1 year
  • Signed by a NP, PA, LSW, RN, etc
  • Improperly altered
  • Post-dated
  • Improperly signed and dated
    • Illegible signatures
    • Stamped or photocopied signatures
    • No credentials
    • Not dated
  • Incomplete

The PCS is not a stand-alone document. A PCS alone does not demonstrate the medical necessity for the medical transport. A PCS in conjunction with medical documentation can be used to support a claim and/or a prior authorization request. Both the PCS and medical documentation need to demonstrate that the services are reasonable and medically necessary. They should provide detailed explanations and descriptions of the patient’s current medical condition. Per 42 CFR §410.40:

In all cases, the provider or supplier must keep appropriate documentation on file and, upon request, present it to CMS. The ambulance service must meet all program coverage criteria including vehicle and staffing requirements. While a signed physician certification statement (PCS), does not alone demonstrate that transportation by ground ambulance was medically necessary, the PCS and additional documentation from the beneficiary's medical record may be used to support a claim that transportation by ground ambulance is medically necessary. The PCS and additional documentation must provide detailed explanations, that are consistent with the beneficiary's current medical condition, that explains the beneficiary's need for transport by an ambulance…

The PCS needs to contain detailed information. Simply writing on the PCS form “needs medical transport” or “bed confinement” is not enough to support medical necessity. For “bed confinement” to be used, the patient must meet the following 3 criteria:

  • Unable to get up from bed without assistance
  • Unable to ambulate
  • Unable to sit in a chair or wheelchair

Bed confinement is not the sole criterion for determining medical necessity. Other factors can be taken into consideration which can include but is not limited to:

  • Severe obesity
  • Contractures/fractures
  • Falls
  • Wounds that require pressure relieving devices
  • Needs advanced airway management or IV vasopressor medication
  • Musculoskeletal/neurological issues impairing their mobility/support

Whether the patient is bed confined or has another medical condition listed on the PCS form, there needs to be documentation to support medical necessity. When submitting a prior authorization request or responding to an ADS letter, you need to submit both the PCS and medical documentation.



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