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Changes Coming to the PCS

November 07, 2019

In the same Final Rule that brought us the cost data collection mandate, the Centers for Medicare and Medicaid Services (CMS) announced changes to the rules surrounding a Physician Certification Statement, or PCS. 

Starting January 1, 2020, there will be a significant change both in the form used, the name of the form, and who can sign the form. To break it down, CMS has separately defined two types of certification statements: A Physician Certification and a Non-Physician Certification.

Physician Certification: A statement signed by beneficiary's attending physician

Non-Physician Certification: A statement signed by an individual other than the beneficiary's attending physician who has personal knowledge of the beneficiary's condition at the time the transport is ordered or the service is furnished and is employed by the beneficiary's attending physician, or by the hospital or facility where the beneficiary is being treated and from which the beneficiary is transported.

Additionally, CMS will expand the list of non-physicians who can sign a form in those cases where the non-emergency transport is either unscheduled or scheduled on a non-repetitive basis. Currently, the list includes:

  • Physician assistant
  • Nurse practitioner
  • Clinical nurse specialist
  • Registered nurse
  • Discharge planner

With the new changes, CMS indicates it now believes a few other individuals (who, like the other approved signers, work for the attending physician or hospital, and have personal knowledge of the beneficiary's condition at the time the transport is ordered or service is furnished) have similar skills to the established list of signers: 

  • Licensed practical nurse 
  • Social worker 
  • Case manager 

Interestingly, CMS has never mandated a particular format for a PCS. According to CMS, it wants to emphasize how it's not the format that matters, just that the form contains the right information to clearly illustrate medical necessity.

So, speaking of the form, the prevailing wisdom is it needs to change in two primary ways:

  • The title should be amended to reflect "Medical Necessity Certification Statement" (or something similar) 
  • New fields must be added for the new signers 

If further changes or best practices become available prior to January 1, Cornerstone will make sure its clients are aware. Likewise, we will update our recommended forms and ensure our clients have access to them in anticipation of January 1.

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