Ambulance Cost Collection
All AAA members and recipients of the SAVVIK Cost Data Collection Grant have access to our AMBER software, which allows services to enter their data in preparation for the federally mandated Cost Data Collection process. AMBER also includes a shorter cost survey, which we are encouraging all services to complete to assist our efforts with the Balance Billing Federal Advisory Committee. Access AMBER here.
CMS Ambulance Cost Data Collection Overview
What is Cost Collection?
Following the passage of the Bipartisan Budget Act of 2018, all ambulance services that bill Medicare will be required to report certain cost related data to CMS. The reason CMS is collecting cost data is to assess the adequacy of the Ambulance Fee Schedule. Cost collection was scheduled to start in 2019 but has been delayed due to the COVID-19 pandemic.
Why is Cost Collection Important?
This is the first time that ambulance service cost-related data has been systematically collected and analyzed by CMS. The American Ambulance Association (AAA) believes that this cost collection process will reveal that the Ambulance Fee Schedule is inadequate to reimburse ambulance service providers for the provision of ambulance services. The CMS ambulance cost collection will likely set Medicare payment policy for many years to come. Additionally, this data will be publicly available and will likely be used by CMS and other payors to structure their reimbursement rates.
What if I Don’t Report My Cost Data?
EMS agencies that fail to report their cost data to CMS will have a 10% reduction in their reimbursement from CMS for a period of one year. Additionally, failure to accurately report your agency’s cost data may result in a skewed analysis of ambulance service delivery resulting in inaccurate EMS service delivery cost-related data. Given that the last time the Medicare reimbursement model was last updated over 20 years ago, Inaccurate cost data may set Medicare payment policy for decades to come.
How is the American Ambulance Association helping EMS agencies prepare for CMS cost data collection?
The American Ambulance Association has created Ambulance Cost Education (ACE) – a set of tools and information created by industry experts to prepare for the CMS cost collection requirements. With in-depth educational programs, topic-focused webinars, and cutting-edge tools, including AMBER, the AAA’s cost collection software, Ambulance Cost Education is a turnkey solution to learning and thriving with the CMS cost data collection requirements.
What Do Ambulance Services Need to Do?
There are many things that EMS agencies need to be doing now to prepare for when they are selected to electronically report.
- Check the Provider Enrollment and Chain of Ownership System (PECOS) to ensure your enrollment data is accurate and up to date
- Check the CMS Ambulance Services Resource Page to see if your EMS agency has been selected to report.
- Access AMBER, the AAA’s cost collection software which was specifically designed around the CMS cost collection requirements. Familiarize yourself with the process and start entering & testing your data now.
- Attend the AAA’s Ambulance Cost Education (ACE) programs (in-person & virtual) to ensure that you and your team understand what cost collection data elements must be reported and how they are calculated.
- Establish a Cost Collection Project Manager for your agency.
Do you have a question related to Cost Data Collection? Email our team of experts at AceFaculty@ambulance.org!
Five Reasons to Comply With Ambulance Cost Data Collection
Q: With everything happening with COVID-19, is Cost Collection going to get delayed or pushed back?
A: CMS announced that it has modified the data collection period for the ground ambulance services that were selected to report in Year 1 and Year 2. Under the current law, these organizations will now be required to begin collecting their cost related data beginning on January 1, 2022 and ending on December 31, 2022. These organizations will be required to report their 2022 cost data by May 1, 2023.
Q: How does the American Ambulance Association plan to continue with ACE Workshops given the stay at home orders, ban on large gatherings, and social distancing standards?
A: The American Ambulance Association and ACE Faculty have recorded the entire ACE cost collection educational content which will be available on the EMS learning management platform, Prodigy EMS. These programs, along with twelve previously recorded ACE webinars extensively cover the CMS cost collection requirements to ensure that your organization is prepared to accurately report your cost related data.
Q: I heard there was a scholarship or grant program for smaller services, is that true?
A: Yes! The Savvik Foundation and the American Ambulance Association have launched a grant program available to Savvik member ambulance services who are classified as rural or super-rural and who are preparing to comply with the Cost Data Collection program through the Centers for Medicare and Medicaid Services. Through Savvik Member purchases under contracts, the Savvik Foundation was able to fund grant dollars through the American Ambulance Association (AAA). Through this grant, services classified as rural or super-rural will be eligible to receive a one-year AAA Ambulance Cost Education Gold subscription, which includes access to experts on cost collection, access to AMBER software, and free registration to Webinars and online educational programs. Apply now!
Q: Can you please define what is included in the term “stipend”?
A: The response in the Final Rule regarding comments about what should be included when responding to “stipends and benefits” for volunteer labor:
“Commenters also stated that the definition of stipends and benefits for volunteer labor should be broadened to include all forms of compensation from the ground ambulance organization such as insurance, stipends, or other forms of compensation. The data collection instrument collects information on volunteer hours and total compensation of any type from the ground ambulance organization so we agree that the definition of “stipends and/or benefits” should be broadened to include all forms of compensation from the ground ambulance organization such as insurance, stipends, or other forms of compensation.”
This would suggest that any form of compensation or benefits that are provided to the volunteer must be included in the compensation for that volunteer employee.
Q: Can you please define the term “volunteer”?
A: The response from the Final Rule regarding volunteers: “Volunteers may receive some forms of compensation but are not considered full or part-time employees if they are not paid a minimum wage in return for full or part-time labor.”
Q: Are municipally based ambulance agencies a shared service?
A: Generally, most government-operated ambulance services are operating on a shared services model. In other words, there is an entity that provides some goods, services, or functions on behalf of the ambulance service that are not reflected or accounted for in their organization’s budget. For example, a fire department based ambulance typically does not have a person handling human resource related functions. This is typically handled by a person whose costs are paid by the municipality and not necessarily itemized in the ambulance service’s budget. In this instance, the EMS service would need to find out and allocate a portion of the HR person’s costs to the fire-based EMS service.
E-mail our ACE Faculty at AceFaculty@ambulance.org for an answer specific to your organization!
Q: Does the relocation of an ambulance to an area during a surge qualify as a standby, count towards a non-transport, or is it able to be counted at all?
A: This will be answered in Question 2 in Section 5. They ask for total responses regardless of level of service or geography. This is where those responses will be reported.
Q: What year are we to be tracking costs? I thought it was to be 2020…?
A: If you were picked to report for reporting year 2020 or 2021, you will be reporting your 2022 cost data. Even if your cost data collection reporting year has been delayed, you should still be tracking costs! The first year data is reported will likely not be the most accurate or successful year. Due to the pandemic, ¾ of the EMS organizations that are required to report will be reporting on the 2022 cost collection year. Given that these organizations will all be reporting the first time in 2022, it is important that organizations get proficient at collecting their cost data.
Q: Isn’t it true that we cannot access or use AMBER software until later, or 2022?
A: Amber is included in AAA membership and is available now. If you’re unsure of your login credentials, contact us for help, or use the ‘Forgot Your Password?’ option on the login page. We encourage all member services to log in and start entering data for cost collection, balance billing, and PRF surveys now.