Zip Code Delay Comment Letter
On December 30, 2014, AAA submitted a comment letter to CMS asking the Agency to delay implementation of the changes in zip codes losing their rural status starting in 2015. In its comment letter, the AAA based the one-year delay on the lack of proper notice of the changes in the geographical delineations of zip codes and the omission of a small entity impact certification in the proposed or final rules. In the proposed rule, CMS stated only 122 zip codes would lose rural status but in the final rule cited 3,038 zip codes switching from rural to urban. The AAA was able to get that number corrected to 1,599 zip codes but believes CMS still needs to delay implementation of the change for one-year to give ambulance service providers adequate time to determine and budget for the loss of revenue.