Trauma Activation Fee

History

Beginning in 2007, the Centers for Medicare and Medicaid Services (CMS) authorized hospitals designated as “trauma centers” to bill and receive payments for critical care services using specific codes and charges that capture the level of expertise and resources used in the triage and care of individual trauma patients. The CMS rules, can be accessed here.

The CT Legislation and Purpose

In 2019, Public Act 19-117 Sec. 245 modified Connecticut General Statute Section 19a-644 to authorize the Office of Health Strategy to obtain data and information from short term acute care general and children’s hospitals on charges for trauma activation fees.

What is the statutory authority for this new filing requirement and when is it due?

Effective February 2020,Public Act 19-117 Sec. 245requires the filing of this information no later than February 28, 2020 and annually thereafter.

What is Trauma Activation Fee?

It is a one-time occurrence in association with deployment of the hospital’s specialized trauma response team. The related reimbursement for this occurrence is commonly known as a “trauma activation fee.” A primary purpose of the CMS trauma team activation codes and related fees payment system is to help trauma centers remain financially viable, given the significant cost burden associated with professional and administrative resources needed to achieve and maintain the advanced level of readiness and capability of their critical care services.

Billing

Revenue code series 68x can be used only by trauma hospitals designated by the state or local government. Different subcategory revenue codes are reported by designated Level 1-4 hospital trauma hospitals. CMS created G0390, Trauma response team activation associated with hospital critical care service, effective January 1, 2007, which is assigned to APC 0618, and Critical Care with Trauma Response.

To determine whether trauma activation occurs, providers are to follow the National Uniform Billing Committee (NUBC) guidelines listed in the Medicare Claims Processing Manual, Publication 100-04, Chapter 25, § 60.4.CMS Manual

What is a designated trauma center?

States designate and license trauma centers and the American College of Surgeons (ASC) verify if the designated centers have the resources listed in the Resources for Optimal Care of the Injured Patient on-site. Each center achieves and maintains its designation through a self-funded rigorous verification process administered by ACS.

How many designated trauma centers in Connecticut?

Connecticut has 13 adult and/or pediatric trauma centers designated and licensed by the Department of Public Health The American College of Surgeons. The very rigorous trauma center re-verification process by the ACS takes place every three years.

Trauma Centers in Connecticut

Trauma Level I	Trauma Level II	Trauma Level III
1. Connecticut Children’s Medical Center (Pediatric)	1. Bridgeport Hospital 2. Danbury Hospital	1. William W. Backus Hospital
2. Hartford Hospital	3. Norwalk Hospital	2. Hospital of Central CT
3. Saint Francis Hospital and Medical Center	4. St. Mary's Hospital 5. St. Vincent’s Medical Center
4. Yale-New Haven Hospital (Adult, Pediatric)	6. Stamford Hospital 7. Waterbury Hospital

What is a trauma center level?

ACS provides detailed criteria to assist trauma centers in establishing policies to set the right level of response in a trauma team activation based on three key domains: the patient’s physiologic status, the patient’s anatomic status, and the mechanism of injury.

A trauma center’s policies also may use other factors to optimize trauma care, including patient’s age, bleeding disorders, burns, end-stage renal disease, advanced pregnancy, time-sensitive extremity injuries, CPR, blunt force or penetrating trauma, and other similar elements.

Every trauma center has a policy that is consistent with the ACS guidelines to outline how the hospital will respond to critical care patients. Table 2 provides a summary of the capabilities and resource needs for each trauma center designation level. CMS rules, ACS and NUBC also provide additional information and current updates to trauma activation rules, charges and payments.

Trauma Center Levels Resource Needs and Capabilities

Elements of Capabilities and Resources	Trauma Center Levels
Elements of Capabilities and Resources	Level I	Level II	Level III
General description	Center serves as comprehensive regional resource and is a tertiary care facility central to trauma system Provides total care for every aspect of injury- from prevention through rehabilitation	Facility able to initiate definitive care for all injured patients	Facility has demonstrated an ability to provide prompt assessment, resuscitation, surgery, intensive care, and stabilization of injured patients and emergency operations
24-hour in-house immediate coverage	By general surgeons	By general surgeons	By emergency medicine physicians
Onsite prompt availability	Specialty care in orthopedic surgery, neurosurgery, anesthesiology, emergency medicine, radiology, internal medicine, plastic surgery, oral and maxillofacial, pediatric, critical care, etc.	Specialty care in orthopedic surgery, neurosurgery, anesthesiology, emergency medicine, radiology, and critical care	General surgeons, and anesthesiologists
Referral source	Is a referral source for communities in nearby regions	May refer tertiary care needs such as cardiac surgery, hemodialysis, and microvascular surgery to a Level I Trauma Center	Have developed transfer agreements for patients requiring more comprehensive care at a Level I or Level II Trauma Center
Quality	Incorporate a comprehensive quality assessment program	Incorporate a comprehensive quality assessment program	Incorporate a comprehensive quality assessment program
Prevention and education - staff	Provide continuing education of the trauma team members	Provide trauma prevention and continuing education programs for staff	Offer continued education of the nursing and allied health personnel or the trauma team
Prevention and education - public	Provide leadership in prevention and public education to surrounding communities Operate an organized teaching and research effort to help direct new innovations in trauma care	Involved with prevention efforts and must have an active outreach program for its referring communities	Involved with prevention efforts and must have an active outreach program for its referring communities
Programs offered to patients	Offer programs for substance abuse screening and patient intervention	N/A	N/A
Volume requirements	Meet minimum requirement for annual volume of severely injured patients	N/A	N/A

When and how should trauma fee information be reported?

Hospital should file the required information as a part of their Annual Reporting Filing through Hospital Reporting System as follows:

Report 24A - Hospitals Trauma Activation Fee policies and procedures in effect for the hospital’s most recently completed fiscal year, duly dated. The policies and procedures should include how hospitals are documenting the practice of charging trauma activation fees when services are provided in the hospital’s emergency room. The documents should also include the composition of the trauma team by clinical staff and specialty, when it is activated, when a patient is billed and any other related charges that are included in the bill.
Report 24B -Hospitals should submit a separate file that contains the number of discharges billed a trauma activation fee, and the range of and total fees charged when a hospital’s trauma team is activated for a patient emergency for the most current full hospital fiscal year.
The Hospital Data Filing Instructions at this link of the OHS website contains an Excel file template to be completed and submitted to ensure reporting consistency among all hospitals.
Instructions for uploading all required information are at this link