CMS Issues Final Rule on the Reporting and Return of Medicare Overpayments

On February 12, 2016, the Centers for Medicare and Medicaid Services (CMS) issued a final rule titled “Medicare Program; Reporting and Returning Overpayments.”  This final rule would implement Section 6402(a) of the Affordable Care Act, which imposed a 60-day requirement on Medicare providers and suppliers to report and return overpayments.  The provisions of this final rule will go into effect on March 16, 2016.

The final rule implements changes that were first proposed as part of a February 16, 2012 proposed rule.  The final rule can be viewed in its entirety by clicking here.


Section 6402(a) of the Affordable Care Act requires health care providers and suppliers to report and return a Medicare overpayment within 60 days of the date such overpayment is “identified”.  Any overpayment not returned within this timeframe would become an “obligation” under the False Claims Act.  As a result, any ambulance service that is found to have knowingly retained an overpayment beyond the 60 day period could be subject to False Claims Act liability.  In addition, violations may also subject an ambulance company to civil monetary penalties and possible exclusion from the Medicare program.

Provisions of Proposed Rule

Definition of an “Overpayment”

In the final rule, CMS defined an overpayment as “any funds that a person has received or retained under title XVIII of the Act to which the person, after applicable reconciliation, is not entitled under such title.”  CMS noted that this definition is mirrors the definition of an overpayment that appeared in Section 6402(a) of the Affordable Care Act.
CMS cited examples of certain common overpayments in the proposed rule, including:

  • Payments for non-covered services;
  • Payments in excess of the applicable Medicare allowable
  • Errors and nonreimbursable expenditures included on a cost report;
  • Duplicate payments; and
  • Payment from Medicare when another payor had primary responsibility.

For ambulance providers and suppliers, another common area of overpayments would be payment for excessive mileage.

Note: in the final rule, CMS clarified that, in instances where the paid amount exceeds the appropriate payment to which a provider or supplier is entitled, the “overpayment” would be limited to the difference between the amount that was paid and the amount that should have been paid.  For example, if the overpayment was the result of a claim incorrectly being billed as an ALS emergency, rather than a BLS emergency, the overpayment is not the entire amount of Medicare’s payment.  Rather, the overpayment is limited to the difference in Medicare’s payment for the two base rates.

When an Overpayment has been “Identified”

In its proposed rule, CMS indicated that an overpayment would be “identified” if the ambulance provider or supplier: (1) had actual knowledge of the existence of the overpayment or (2) acted in reckless disregard or deliberate ignorance of the existence of the overpayment.  CMS indicated that this definition was intended to prevent providers and suppliers from deliberately avoiding activities that might uncover the existence of potential overpayments, such as self-audits and outside compliance checks.

CMS further stated its belief that the Proposed Rule would, in some instances, place an affirmative burden on providers and suppliers to investigate whether a potential overpayment exists.  Specifically, CMS indicated that “in some cases, a provider or supplier may receive information concerning a potential overpayment that creates an obligation to make a reasonable inquiry to determine whether an overpayment exists.”  If the provider or supplier then fails to reasonably inquire, it could be found to have acted with reckless disregard or deliberate ignorance.

In the final rule, CMS indicated that an overpayment will be deemed to have been identified to the extent “a person has, or should have through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment.”

Thus, the final rule makes two important changes to the standard of when an overpayment is identified.  The first change is to clarify that an overpayment has not been identified unless and until the provider or supplier is able to quantify the amount of the overpayment.

The second change was to remove the language related to “reckless disregard” and “deliberate ignorance”.  CMS replaced these terms with a standard of “reasonable diligence”.  Under the new standard, an overpayment is identified on the date you can actually quantify the size of the overpayment, or the date on which you would have been able to quantify the overpayment had you proceeded with reasonable diligence to investigate the possibility of an overpayment.  For these purposes, CMS indicated that reasonable diligence would be established to the extent you can demonstrate a timely, good faith investigation of any credible report of a possible overpayment.  Note: CMS indicated that an investigation should take no more than 6 months from the date of receipt of credible information, except in extraordinary circumstances.

To see the impact of these changes, consider the following scenario:

You receive an anonymous report on your compliance hotline that a recent change to your billing software has resulted in the mileage for all Medicare claims being rounded up to the next whole number (as opposed to being submitted with fractions of a mile).  Based on this report, you begin an investigation, and quickly come to the conclusion that the anonymous report is correct.  However, it requires an addition 4 months to review every claim submitted to Medicare since that software change, and to calculate the actual amounts you were overpaid.

Under the standard first proposed by CMS, it was unclear whether the 60-day clock to return over payment started on the day you confirmed the software problem, or whether you have time to look at your entire claims universe to calculate the actual amounts you were overpaid.  By contrast, under the standard set forth in the final rule, it is clear that the overpayment would not be “identified” until you can quantify the actual amounts you had been overpaid.  In the above example, you completed your investigation within 6 months, meaning you would have satisfied the new “reasonable diligence” standard.  Therefore, assuming you make a timely report and refund of the amounts you were overpaid, you would have no liability under the False Claims Act.

Situations in Which a Provider or Supplier would have a Duty to Inquire

In the proposed rule, CMS provided some examples of situations where a provider or supplier would be deemed to have received a credible information regarding a potential overpayment, including the following situations:

  • Where a review of billing records indicates that you were incorrectly paid a higher rate for certain services;
  • Where you learn that the patient died prior to the date of service on a claim that has been submitted for payment;
  • Where you discover that the services were provided by an unlicensed or excluded individual;
  • Where an internal audit discovers the presence of an overpayment.
  • Where you are informed by a government agency of an audit that discovered a potential overpayment, and where you fail to make a reasonable inquiry;

In the final rule, CMS confirmed its belief that official findings from a government agency (or its contractors) would constitute credible evidence of a potential overpayment, and would therefore trigger a provider’s or supplier’s obligation to conduct an investigation with reasonable diligence.  If the provider or supplier ultimately agrees with the Medicare contractor’s findings, it would qualify as having “identified” an overpayment, which would trigger the 60-day period for reporting and refunding that overpayment.  CMS further indicated that when the provider confirms the audit’s findings, the provider or supplier may be deemed to have credible evidence of additional overpayments (i.e., claims presenting the same issues, but which fall outside the contractor’s audit period) that may require further investigation.   CMS did agree, however, that where the provider or supplier elects to appeal the contractor’s findings, it would be reasonable to hold off on conducting an investigation into similar claims until such time as the overpayment identified by the Medicare contractor has worked its way through the administrative appeals process.

Counting 60-Day Period

In the final rule, CMS indicated that the 60-day period for reporting and returning the overpayment would start on the date the overpayment is first identified (i.e., the date the overpayment is first quantified following a reasonably diligent inquiry.  However, in the event a person fails to conduct a reasonably diligent inquiry, the 60-day period will be deemed to run from the date the provider or supplier first received a credible report of a possible overpayment (assuming the provider or supplier was, in fact, overpaid).

Process for Reporting Overpayments

In its February 2012 proposed rule, CMS had indicated that it would require ambulance providers and suppliers to report and return overpayments using the existing process for voluntary refunds.  At that time, CMS also proposed that the overpayment report contain 13 required elements, including a brief statement of the reason for the overpayment, and a description of the steps the provider or supplier intended to take to ensure that the same error would not occur again.  At the time, CMS further indicated that it would develop a uniform reporting form that would replace the various forms currently in use by its Medicare contractors.

In the final rule, CMS abandoned this formulaic approach to the reporting of overpayments.  Instead, CMS elected to permit providers or suppliers to use any of the following to report an overpayment:

  • An applicable claims adjustment;
  • Credit balance;
  • Self-Reported Refund; or
  • Any other reporting process set forth by the applicable Medicare contractor.

In addition to the processes currently used by Medicare contractors, providers or suppliers can also satisfy the reporting obligations of the final rule by making a disclosure under the OIG’s Self-Disclosure Protocol or the CMS Voluntary Self-Referral Disclosure Protocol.  Note: these processes are generally reserved for situations that involve something more than an isolated billing error.

When reporting an overpayment that was calculated using a statistical sampling methodology, CMS indicated that the provider or supplier must describe the actual process used to obtain a statistically valid sample, and the extrapolation methodology used.

Statute of Limitations

In the final rule, CMS adopted a 6-year “lookback period”.  CMS further clarified that this lookback period is measured from the date the provider or supplier identifies the overpayment.  As a result, an overpayment must be reported and returned only to the extent the overpayment is identified within 6 years of the date the overpayment was received.  Overpayments identified beyond the 6-year lookback period would not be subject to the new regulations.

The 6-year lookback period represents a substantial reduction from the 10-year lookback period originally proposed by CMS.  That 10-year period was intended to coincide with the outer limit of the statute of limitations for False Claims Act violations.  However, after considering comments from healthcare providers and suppliers, CMS agreed that a 6-year lookback period was more appropriate.  CMS noted that the change would significantly reduce the burden these new regulations imposed on providers and suppliers.

Change to Regulations Governing Reopenings

To facilitate the reporting and refunding of overpayments under these new regulations, CMS elected to revise its rules regarding reopenings.  CMS will now permit its Medicare Administrative Contractors (MACs) to reopen an initial determination (i.e., a paid claim) for the purpose of reporting and returning an overpayment.

While seemingly minor, this change is needed to ensure that Medicare’s payment files properly reflect that an overpayment has been refunded.  Otherwise, it would be possible for a claim that had previously been refunded to be selected by a Medicare auditor for postpayment review.  This could lead to the auditor attempting to recoup amounts that had previously been voluntarily refunded.

Share With Your Team: Building Resilience

(from the AAA Employee Assistance Program powered by Ceridean LifeWorks)

All of us face unexpected changes, challenges, and set-backs at some point throughout our lives. How can you learn to keep up a positive attitude and stay strong through life’s unwanted changes and challenges? Here are a few resilience techniques to practice and to help you get through challenging times:

  • Choose to have a positive attitude. There are many things over which you have no control — for example, you can’t control whether the company gets sold and you lose your job. You can’t control whether your child is faced with a serious illness. But you can choose how you respond to the difficulties and setbacks you face.
  • Take care of yourself. The stronger and fitter you are physically, the more resources you will have to face the challenges that life brings you. Practice healthy habits. Make sure you get enough rest, eat a healthy diet, get regular exercise, get out and walk alone or with a friend, and manage feelings of stress. The more you do for yourself, the more resilient you’ll feel during times of challenge and change.
  • Use “traffic light coping.” This exercise, developed by Dr. Williams, works like this: When you start to feel worried, panicked, or angry — when you start to “see red” — stop and relax. Pause. Take some time to breathe deeply to help calm your body and mind. Soften your shoulders. Let your muscles soften slightly. When you feel calmer, you’re ready to move forward.
  • Trust your inner strength. Experts agree that we have strengths we never knew we had until we have to use them. You’ll be amazed at how many personal resources you have that you never even knew about. Remember that change can lead to personal growth.
  • Start with a single step. If you are faced with a challenge that feels big or overwhelming, start with the simplest thing you can do that takes you in the direction you want to be. Ask yourself, “What’s the smallest thing I can do to get started?” Once you’ve thought about it, do it.
  • Let go of your anger. A difficult challenge can cause us to feel angry and upset. These feelings are normal, but they won’t help us move forward. Work through your anger by writing about it, or talking about it with a trusted friend. Try to let go of negative feelings. It’s not easy to do. It takes practice and work. But try. You’ll be amazed at the results.
  • Focus on solutions, not problems. Instead of focusing on what you feel you may be losing, consider what you may gain because of the change. For example, if your job is changing, this may be the opportunity you were waiting for to reassess your work and find new direction.
  • Laugh. Even when things seem to be falling apart around you, try to find time to smile and laugh. It’s very healing and it will help you forget your worries for a few moments. Rent a movie that makes you laugh or spend time with a friend with a good sense of humor.
  • Focus on the things that are good in your life. Count your blessings. Try to appreciate the day-to-day good things in your life now. The more time you spend doing that, the more energy you will have to deal with the problems that you face. A sense of gratitude helps put things in perspective.

For more ideas on staying resilient during times of change, get in touch with LifeWorks—call to speak with a caring, professional consultant anytime, 24/7. You can also go to to explore our online resources including an award-winning booklet, Bouncing Back: Staying resilient through the challenges of life , a recording, Navigating Workplace Change featuring stories and ideas on how to thrive in turbulent times. You can also check out helpful articles like Ten Ways to Bounce Back and Finding Strength in Family and Community, or a podcast, Adjusting to Changes in Your Personal Life. LifeWorks is completely confidential and it’s provided to you at no cost through your organization’s AAA membership.

Call LifeWorks at 800-929-0068 or visit (username: theaaa; password: lifeworks). 

Spotlight: Jerry Glass, Labor Relations Expert

Jerry Glass
F&H Solutions Group
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Tell us a little about yourself.

I was born and raised in New York City. I went to college at Boston University and then moved to Washington, D.C., to attend George Washington University, where I received my master’s degree. It is also where I met my wife, Karen. We have been married for 36 years, but with all the travel I do, I tell people we have only been together for about 15 years! We have two adult children and one son-in-law.

My number one passion is basketball. I live and breathe the sport. I have been playing in a basketball league and enjoying pickup games with a group of guys for more than 30 years. And if you invite me to see a high school, college, or professional basketball game, count me in. Karen and I also love cycling and spinning. We take a cycling trip each summer and have seen some great sites on our bikes.

How did you get into labor relations? Can you give us some background on your professional life?

When I graduated from GWU, my first job was with the Veterans Administration as an analyst. The job required a lot of travel and was really gut wrenching, working with our veterans who had done so much for our country. From there, I worked as a costing/financial analyst for the American Association of University Professors (AAUP) which is a trade association and a union. Then, I moved to the Airline Industrial Relations Conference, which served as the labor policy organization for the U.S. scheduled airlines. I started out as the Director of Labor Relations Research and was promoted to Executive Director and Vice President. After 9 years in that job, I went out on my own as a labor and employee relations consultant. The rest was history as I built my consultancy into a national labor relations and HR consulting firm, F&H Solutions Group.

In addition to running my firm, I also served as the Executive Vice President and Chief HR Officer at US Airways during the airline’s two bankruptcies. Wow, did I learn a lot about restructurings! Thankfully, the airline not only survived, but eventually became part of the largest airline in the world.

I have been fortunate to have an amazing team working with me. Together, we provide labor relations advice and negotiations expertise to many of the most important industries in the country, including transportation, construction, property management, media and more.

How have you seen labor relations issues impact business?

[quote_right]”People involved in labor relations must be great communicators and even better listeners.”[/quote_right]Employees are a huge part of an organization’s success. When unions represent employees, it adds a level of complexity to how you manage employees. People involved in labor relations must be great communicators and even better listeners. Labor relations has an impact on a company’s bottom line and it is crucial for employers to tread carefully, work cooperatively, and be proactive when dealing with unions.

How can FHSG help AAA members with their labor relations issues?

We would like to help members understand the dynamics involved in labor-management relations. Whether it’s learning how to communicate effectively with unionized employees, providing research on CBAs in the industry, or understanding the different aspects of a union campaign, we can help you devise a labor strategy. We will offer a free initial consultation to all AAA members. In addition, we will provide insightful blogs and webinars on topics related to labor relations, proactive employee relations and leadership/managerial skills.

Any parting thoughts or last words?

While it is not uncommon for management at newly unionized companies to feel intimidated, it is crucial that management continue to do their jobs and effectively manage employees. Over time, you will learn to work with the union and how to maintain a positive, inclusive and safe workplace culture for your employees. Management cannot allow union activity to disrupt the ability to manage and ensure the integrity of the day to day operation.

WTAE Shows 25% of Ambulance Calls Unpaid

WTAE Pittsburgh’s Action News recently published a great video investigative piece by Paul Van Osdol on the realities of ambulance funding.

So who pays for these and other non-transport calls?

“The folks that go to the hospital end up paying for the 25 percent that we don’t transport,” Porter said.

But even that does not cover the entire cost, and as a result, ambulance companies are hurting.

A survey of Allegheny County EMS services found 75 percent of them are losing money. On average, they collect only 43 percent of the amount they bill.

“That is frightening when you think about the EMS system as a whole,” Porter said. “The risk is burnout of EMS crews, overworked EMS crews, delayed response time, inadequately trained staff.”

Read the full article, and see their fantastic video, over at

Watch Now

Chicago Regional Workshop at Superior Air-Ground Ambulance Service

A Comprehensive Compliance Strategy-How to Structure Your Billing Office for Integrity and Accountability

The Comprehensive Compliance Strategy One-day Workshop is intended to provide guidance to Patient Accounts Managers/Supervisors and lead billing staff on the need for a comprehensive compliance strategy. The workshop provides a hands-on “Deep Dive” format that will allow for in depth discussion of your billing office operations. It is our goal to have attendees leave with actionable information on the reimbursement, compliance, and practical aspects of running a billing office. NAAC approved for 6.5 CEU hours.

$299 for individual members, $279 group rate (2 or more)
$599 for non-members, $579 group rate (2 or more)




Superior Air-Ground Ambulance Service
395 W Lake St
Elmhurst, IL 60126
Recommended hotel: SpringHill Suites, Elmhurst/Oakbrook


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9:15am State of the Union

The first session will cover a current state of the industry as it relates to fraud and abuse in the ambulance business, CMS and OIG practices, investigative trends and the need for payment reform. The session will identify those fraudulent and unintended billing errors that led to action by the oversight agencies. Also, was it much to do about nothing? We will an update on the ambulance industry’s transition to ICD-10.

10:45am Deep Dive: The Lion in Sheep’s Clothing-Properly Vetting Employees

This in depth session will teach you how to develop a comprehensive background screening process for all staff members, both new hires and existing staff, particularly those handling ambulance claims. Attendees will learn what screening they should be performing on employees and the law on when they can and should run credit reports on those in financially sensitive positions. Attendees will leave with a checklist and tips that they can use at their own services to ensure that they properly document their processes.

12:00pm- Your Infrastructure: Establishing Partners Not Peddlers

Our noon session is an expose on establishing or improving upon vendor partnerships in the billing office, both from a compliance standpoint, as well as achieving the best type of partnerships for the EMS organization. The session will cover the use of indemnification clauses in the Business Associate Agreements, ensuring the vendor has a current Cyber Insurance Policy, out clauses for non-performance, GEO Screening for Vendor Employees (and their contractors!), and more. Then, the session will move into a larger scope for achieving the best value for the provider with advanced strategies like: Looking for Partners not Peddlers, measuring net-back gain (vs. rate), using no obligation test files, comparing multiple vendor results, holding vendors accountable, interviewing negative and positive references, and more.

1:15pm Deep Dive: Raising the Bar—Patient Accounts Policies & Procedures Workgroup

This interactive breakout session, facilitated by both speakers, will address the compliance concerns brought forward by the attendees. During this session we will identify and discuss policies and procedures that will standardize ambulance billing office practices as part of a larger compliance plan. This session will give services a list of recommended Patient Accounts Policies & Procedures that will provide protection from unintended errors.

3:00pm Medicare Update and Court Cases You Need to Understand

An invaluable overview of what you need to know regarding Medicare. Always pithy and delivered at a pace that holds your attention this session will give you the big picture for reimbursement. Brian will also cover court cases and the decisions that may surprise you. These real life examples will help you avoid the common and not so common pitfall.



Scott Moore


Scott A. Moore, Esq. has been in the emergency medical services field for over 26 years.  Scott has held various executive positions at several ambulance services in Massachusetts.  Scott is a licensed attorney, specializing in Human Resource, employment and labor law, employee benefits, and corporate compliance matters.  Scott has a certification as a Professional in Human Resources (PHR) and was the Co-Chair of the Education Committee for the American Ambulance Association (AAA) for several years.  In addition, Scott is a Site Reviewer for the Commission on the Accreditation of Ambulance Services (CAAS).   Scott earned his Bachelor’s Degree in Psychology from Salem State College and his Juris Doctor from Suffolk University Law School.  Scott maintains his EMT and still works actively in the field as a call-firefighter/EMT in his hometown.  Scott is a member of the American Bar Association, the Massachusetts Bar Association, the Society for Human Resource Management, and the Northeast Human Resource Association.

Brian Werfel

3Brian S. Werfel, Esq. is a partner in Werfel & Werfel, PLLC, a New York based law firm specializing in Medicare issues related to the ambulance industry. Brian is a Medicare Consultant to the American Ambulance Association, and has authored numerous articles on Medicare reimbursement, most recently on issues such as the beneficiary signature requirement, repeat admissions and interrupted stays. He is a frequent lecturer on issues of ambulance coverage and reimbursement.

Tristan North


Tristan North serves as the Senior Vice President of Government Affairs for the American Ambulance Association (AAA). Mr. North is a registered lobbyist with more than 15 years of expertise and experience in government affairs. He joined AMG in 2002 and has been a lobbyist for the AAA since 1996. As the Senior Vice President of Government Affairs for the AAA, Mr. North oversees all aspects of the legislative and regulatory priorities of the Association before the Congress and Federal agencies. He is the lead lobbyist for the AAA and is responsible for shaping and implementing the public policy of the organization. Prior to joining AMG, Mr. North was Director of Government Affairs for the AAA at Hauck & Associates. Mr. North spent five years in the Government Affairs Division of Fleishman-Hillard representing the interests of health care and financial service clients before the Congress. For four of those years, Mr. North was a member of the Fleishman-Hillard team that represented the AAA on legislative and regulatory issues. Mr. North began his career in politics with the U.S. House of Representatives Committee on Financial Services where he worked as a professional staff member and investigator. While on the Committee, he was responsible for issues involving anti-counterfeiting efforts, the redesign of the currency and the review of the U.S. banking system. Mr. North graduated from Babson College in Wellesley, MA with a B.S. in Finance

Brian Choate

2Brian’s diverse background consists of 18 years of finance, technology and revenue cycle. His passion for out-of-the-box thinking and innovation creates a perfect storm for challenging the status quo. Brian’s start in revenue cycle began in 2009, when creating a technology that uncovers billable insurance(s) for misclassified self-pay accounts. Brian currently serves as faculty for the American Ambulance Association’s (AAA) Reimbursement Conferences, and often speaks on reimbursement technologies at State and National EMS conferences.  When not working, Brian enjoys playing drums and spending time with his wife and three children, ages 17, 3, and 1.

Please contact Desiree LaFont if you would like additional information for this event. or 703-610-9038

Share News Stories and Press Releases with AAA

AAA members, do you have a great news story or press release to share with fellow members? We’d love to help. Submit links to content published on non-AAA sites below.

  • News articles may be included in the AAA Digest e-newsletter and/or blog.
  • Press releases are accepted as they relate to heroism, community service, merger and acquisition announcements, and other noncommercial activities. Please note that commercially-focused or product-specific press releases cannot be shared by AAA as a matter of policy.

Stories can be about your ambulance service, your employees, services near you, policy, or other topics that you feel may be of interest to other members. Thank you for sharing your stories with us!

Would you like to write or speak FOR AAA? Read more.

Please note that AAA reserves the right to decline to publish any content for any reason. Only AAA members are eligible to submit content.

  • Submitter Name
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Musings on 2014 Medicare Payment Data (Part 1)

by Brian S. Werfel, AAA Medicare Consultant | Updated February 2, 2016

Every year, the Centers for Medicare and Medicaid Services (CMS) releases data on Medicare payments for the preceding year.The 2015 Physician/Supplier Procedure Master File (PSP Master File) was released in late November 2015.This report contains information on all Part B and DME claims processed through the Medicare Common Working File with 2014 dates of service.

The headline number is that Medicare spent $4.968 million on ambulance services in 2014.This represents a slight increase (0.67%) over the amounts spent on ambulance services in 2013.

Over the next few blog posts, I will be digging a bit deeper into these numbers to highlight a few long-term trends that I believe are noteworthy.

Increase in Medicare Ambulance Volume Trails Increase in Medicare Enrollment

The number of allowed ambulance services has grown steadily since 2007.Using data from the annual PSP Master Files, the number of allowed ambulance transports increased from approximately 17.5 million transports in 2007 to 20.8 million transports in 2014.The Office of the Inspector General and other government agencies have pointed to numbers like these as evidence that ambulance services face an increasing program integrity problem.

While a superficial analysis might suggest that this growth is problematic, I would argue that this growth must be viewed in its proper context.Over this same period of time, CMS Medicare Enrollment Reports show that the Medicare beneficiary population has grown from 44.1 million beneficiaries to approximately 54 million beneficiaries.All things being equal, one would expect the volume of ambulance transports to increase as the total beneficiary population increases.

When one compares the growth of ambulance volume to the growth of the Medicare population, a different narrative becomes apparent.As the chart on the right shows, with the exception of 2011, the increase in ambulance transports has consistently trailed the overall growth of the Medicare population since 2010.This reflects the fact that the earliest members of the Baby Boomer generation started to turn 65 in 2010.In other words, once you adjust for the increase in the Medicare population, ambulance transport volume has been essentially flat over the past 5 years.

Something to keep in mind the next time someone cites the increase in ambulance transports as proof that our industry has failed to adequately police itself.

Have an issue you would like to see discussed in a future Talking Medicare blog post? Please write to me at

AAA Members Save on EMS Today!

In 2016, AAA is working closely with the Journal of Emergency Medical Services (JEMS) to bring members even more high-quality educational opportunities.

As such, we are proud to offer members a special Buy-One, Get-One discount on Gold Passport registrations to the upcoming EMS Today conference in Baltimore, February 25–27. Register for a Gold Passport with code AAA before February 12, and you will receive a code for a free Gold Passport to share with a friend!

Learn More

EMS Today (a JEMS conference)
February 25–27, 2016
Baltimore Convention Center