Coder's Corner

by R. Lawrence Reed III, MD, FACS, FCCM & Thomas Esposito, MD, MPH

This message was sent to AAST this past year for our Coding/Billing Committee:

I have 3 questions regarding Trauma Activation fee.

68x revenue code description.

It states if you have:  Patients who are “drive-by” or arrive without notification cannot be charged for activations, but can be classified as trauma under patient type –“trauma for statistical and follow up purposes.

Question 1:  So if there is a GSW dropped off by private vehicle we cannot charge the Level 1 Trauma Activation?

Question 2:  If any patient arrives by private vehicle can a Trauma Activation feel be added?

Also states:  Only patients for whom there has been PRE-HOSPITAL notification, who meet either local, state or ACS field triage criteria, or delivered by inter-hospital transfers, and are given the appropriate team response, can have the activation fee charge.

We have a case patient arrived @ 0858, patient is activated @ 1032 after work up.  The insurance is stating per NUBC guidelines, a trauma activation requires “Notification of key hospital personnel in response to triage information from pre-hospital caregivers in advance of the patient’s arrival.” Patients who arrive without notification cannot be charged for activation.  The insurance is denying the activation fee.

Questions 3:  So if a patient arrives by EMS but it activated as a trauma after patient arrival can the Trauma Activation Charge be added?

Reed:

The rules are that trauma activation charges (Revenue code 068x, where the “x” applies to the designation level of the trauma center  -- i.e, “1”, “2”, “3”) can only be applied when the trauma center & its trauma team are notified by EMS providers of the patient’s pending arrival at the facility.

The charges will be denied for any of the following:

1. the hospital is not a designated or verified Trauma Center,
2. no pre-arrival notification was provided,
3. the individual(s) providing the pre-arrival notification were not pre-hospital care providers.   (In general, families, acquaintances, taxi or Uber or Lyft drivers, and other non-EMS providers would not be considered appropriate pre-hospital care providers).

The issue of whether or not the patient meets ACS or CDC field triage criteria is usually less critical and, as far as I know, has not been audited.  However, that is a concern that should be addressed by any facility seeking to bill and receive payment for activation charges.

 So, in response to the submitted questions:

Question 1:  So if there is a GSW dropped off by private vehicle we cannot charge the Level 1 Trauma Activation? That is correct.  You cannot charge because there was no pre-arrival notification and the patient was not transported by EMS providers.

Question 2:  If any patient arrives by private vehicle can a Trauma Activation feel be added?  As I understand the rules, the only type of situation where a private vehicle could work would be if the driver is an EMS provider bringing in their spouse or child or even an unrelated individual and calls the appropriate party at the receiving verified or designated Trauma Center to initiate the appropriate activation.  Even then, any questions by the payer could initiate an audit which would need documentation that the requirements were satisfied.

It is useful to understand that the Trauma Activation Fees were developed and approved a number of years ago by the Trauma Center Association of America (TCAA).  The goal was to provide a means of paying for the costs of maintaining a trauma center.  There are additional costs incurred in managing a trauma center, such as salaries for the staff (Trauma Program Manager, Trauma Medical Directory, Trauma Registrars, etc.), call pay for the various physician specialties to be available – sometimes in-hospital – on a 24/7 365 bases, verification or designation fees, and others.  However, there was no process for hospital reimbursement for establishing and running a trauma center other than from the overhead available from patient revenues.  The Trauma Activation Fee is one source of revenue that can be specifically linked to the hospital’s status as a Trauma Center, but, as is the case with most payments by 3^rd parties, there are some strings attached.