by Thomas J. Gilbert (Summer 2016)

Emergency medical technicians employed by an Illinois fire protection district or fire department have until June 30, 2016 to enroll in IMPACT, the state’s new Medicaid management system. For the past 34 years, Illinois has used the Medicaid Management Information System (MMIS) to handle claims, including payments and eligibility verification. In an effort to modernize the process, and comply with federal requirements under the Affordable Care Act, Illinois is transitioning to a new cloud-based system. The Illinois Medicaid Program Advanced Cloud Technology (IMPACT) is expected to be fully implemented by 2018.

The massive overhaul, however, is taking longer than expected. Medicaid providers in the old MMIS (such as ambulance services) were supposed to enroll in IMPACT by the end of 2015; however that deadline was pushed back to June 30, 2016. That is the same deadline for “atypical providers,” which include EMTs, drivers, dispatchers, homemakers, and interns. These groups were previously referred to as “waiver program providers,” because they were not enrolled in MMIS. Now, however, anyone who bills for and receives Medicaid payments must register through IMPACT. Even though ambulance companies handle billing, EMTs must enroll because they provide the underlying medical services.

Enrollment in IMPACT involves several steps. First, the ambulance service must enroll before their employees can enroll, because EMTs will need to link to their employer while registering. Most providers enrolling in IMPACT need to obtain a National Provider Identifier (NPI) number through the federal government and file a W-9 with the State Comptroller. However, that is not required for “atypical providers.” Instead, the first step for EMTs is to create an account on IMPACT’s website: impact.illinois.gov. Instructions for doing so are listed in a file on the website, located under “Presentations and Materials,” then “Single Sign On.” By following those steps, applicants will ultimately receive an enrollment application to complete.

Through this enrollment process, EMTs will provide their relevant contact and background information. IMPACT will inform applicants which sections are required as they enter information. They have 30 days to complete the application after starting it. The following instructions can also be found on IMPACT’s website under “Rendering/Servicing Providers.” When selecting “Enrollment Type” within the application, though, EMTs are still considered “Atypical (non-medical) Providers.”

The initial requirement after entering basic contact information is choosing a specialty. Then EMTs need to submit their employer’s provider ID, since they do not handle billing themselves. Next, EMTs must upload a current Public Health License/Certificate. Optionally, they can also upload a DHS State License/Certificate. The IMPACT system will verify the status of these licenses, as well as check other information provided in the application.

The next required step is entering a taxonomy number. There are three codes from which EMTs can choose:

  • Basic EMT (146N00000X)
  • Intermediate EMT (146M00000X)
  • Paramedic EMT (146L00000X)

Lastly, applicants will need to answer a series of questions on the “Provider Checklist” before submitting the enrollment application for approval.

Although the application is completed at that point, there is one final step prior to enrollment. EMTs are classified as a “moderate risk” for screening. According to the Affordable Care Act, the state Medicaid agency must make site visits to verify the information provided by the EMT. These visits will be coordinated after the application has been submitted.

What happens if the provider/paramedic/EMT has not registered and is the treater on an ambulance call? According to IMPACT, after June 30, 2016 the responding/treating agency will not be eligible to receive compensation from Medicaid. There are no other penalties for failure to register, either criminal or civil. This is not a criminal statute, but rather a regulation adopted by duly authorized state agencies. The system is currently available for all providers to enroll. Please contact your attorneys if you or your employees encounter any questions or concerns about the impacts of IMPACT.