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CMS-1403-FC
Comment: A commenter recommended that the existing
language in §424.36(b)(6)(ii)(A) be modified to state that,
in the case of an emergency transport, the general crew
signature on an emergency ambulance incident report is
sufficient to meet the requirements of §424.36(b) and that
a separate crew signature is not required. The commenter
suggested, as an alternative, that if we determine that the
signature of an ambulance employee present during the
transport is necessary, it should be sufficient if the
employee signature on the incident report is obtained
“after the fact,” rather than contemporaneous with the
transport. The commenter stated that it is necessary that
we allow signatures obtained after the transport because
the ambulance crew’s primary concern is taking care of the
patient, not doing paperwork, such as a signed incident
report.
Response: We are not persuaded to modify the
requirement in §424.36(b)(6)(ii)(A) to state that the
general crew signature on an incident report is sufficient
and that a separate crew signature is not required. We
believe that the commenter’s suggestion that any member of
the general crew be permitted to sign the incident report
as evidence that the service was rendered as billed would
not satisfy our integrity concerns, because the general
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