“Soft” and “Compassionate” – Wait, Are We Talking about Billing, Here? Dissecting the OIG Safe Harbors and More
Being part of a government agency brings a unique set of laws and regulations that don’t always apply the same way to the public sector as they do to the private sector. Many municipal EMS agencies have adopted so-called “soft” or “compassionate” billing practices where the patient is not responsible for any cost sharing amounts. That goes against the grain of the general rule that EMS agencies must make reasonable efforts to collect the required co-payment amounts from the patient. Recently, the Office of Inspector General issued a new safe harbor for emergency response ambulance services that expressly permits the “waiver” of the normally required cost sharing amounts. Previously, the OIG issued a safe harbor for ambulance restocking programs. These safe harbors focus on areas where public agencies can benefit. In this session, we will dissect both safe harbor rules and discuss their impact on public EMS agencies and how your agency can best fall under them. With the need for additional revenue streams, we will also discuss ambulance membership/subscription programs and how your agency can structure a membership program that can pass government muster.