CMS Issues Additional Staffing and Licensing Waivers

On May 1, 2020, CMS updated its “COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing.”  The full document can be viewed by clicking here. In the updated FAQ, CMS answers three important questions related to ambulance vehicle and staffing requirements: Expired Ambulance Operating Licenses. CMS was asked whether a ground ambulance vehicle operating under an expired license could nevertheless satisfy the Medicare regulations related to vehicle licensing.  CMS indicated that the ground ambulance would remain in compliance with Medicare Program rules to the extent it was permitted to operate without a renewed license under a valid state or local law, regulation, or legally adequate waiver.  It is important to note that this is not a “waiver” of CMS rules per se.  Rather, CMS correctly noted that additional flexibility being provided is based on the state waiving or relaxing its existing rules related to licensures. Modified Staffing Requirements. CMS was asked whether an ambulance service that staffs its vehicles with personnel that fall below the previously required levels of certification would be in compliance with Medicare Program rules.  The Medicare regulations at 42 C.F.R. §410.41(b) set forth the requirements for vehicle staffing.  These regulations largely defer to state and...

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COVID-19 Uninsured Program Now Includes Air, Water

HHS Updates Guidance on Provider Relief Funding for Uninsured to include Air and Water Ambulance The Department of Health and Human Services recently updated its guidance on the disbursement of provider relief funds under the CARES Act for the testing and treatment of the uninsured.  Previously, HHS indicated that this allocation was only available for the reimbursement of emergency and non-emergency ground ambulance transportation.  However, in its most recent update, HHS has removed the restriction that limited participation to ground ambulance providers and suppliers.  The new guidance indicates that the relief funds are now available for all emergency ambulance transportation and non-emergency patient transfers via ambulance. Thus, it appears that air and water ambulance providers and suppliers are now eligible to receive funding for the treatment of COVID-19 patients.  Is there anything my air or water ambulance organization needs to do to claim reimbursement for treatment of uninsured COVID patients? Yes.  In order to be eligible for payments for the treatment of uninsured COVID patients, you must enroll as a participant in the program.  Enrollment must be done through an online portal that can be accessed at: http://www.coviduninsuredclaim.hrsa.gov. Once my organization enrolls, when can we start submitting claims for reimbursement...

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COVID-19 Financial Impact Calculator

The American Ambulance Association is working nonstop on advocating for financial relief from the impact of the Coronavirus (COVID-19) for our members. Now that ground ambulance service providers and suppliers are receiving federal funding to help partially offset the negative financial impact of the Coronavirus (COVID-19), the Congress is asking for information to substantiate that additional funding is necessary. Instead of providing just anecdotal information on the increased costs and lost revenue from COVID-19, we need to provide more wide-ranging data demonstrating the dire financial situation facing our industry. To this end, the American Ambulance Association has developed a Financial Impact Calculator to gather information from our members to help us make our case for additional financial relief. The Calculator is also designed for members to use in completing the application for more funding under the General Allocation second distribution of the Public Health and Social Services Emergency Fund. Download the  Excel Version of the Financial Impact Calculator as a reference. The Instructions include definitions for fields in both the Excel and online calculators. Your data will be safely stored, and will  be shared only in aggregate. Please DO NOT enter commas or dollar signs  when providing data. The system will (more…)

HHS Provider Relief Tranche 2 Calculator

Use the American Ambulance Association’s simple form to estimate relief you may receive from the second tranche of HHS COVID-19 funding. Please note that not all providers will receive funds. More information about this program as well as access to the form you must complete in the General Allocation Portal can be found on the HHS website. For-profit and non-profit non-governmental providers,  to determine your Net Patient Revenue for the portal, use the following information from your most recently filed tax return. (2019 if filed, otherwise use 2018 numbers). Governmental providers,  enter your revenue generated for the last audited financial year. When completing the form in the portal,  select Tax Exempt Organization. When asked to upload a return at the end, upload your most recent audited financials. Please do not enter commas or dollar signs. A negative number or zero in the Tranche 2 box indicates that you WILL NOT receive funding in tranche  2....

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HHS Announces Plans for Distribution of Remaining CARES Act Provider Relief Funding

HHS Announces Plans for Distribution of Remaining CARES Act Provider Relief Funding By Brian S. Werfel, Esq. March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).  As part of that Act, Congress allocated $100 billion to the creation of a “CARES Act Provider Relief Fund,” which will be used to support hospitals and other healthcare providers on the front lines of the nation’s coronavirus response.  These funds will be used to fund healthcare-related expenses or to offset lost revenue attributable to COVID-10.  These funds will also be used to ensure that uninsured Americans have access to testing a treatment for COVID-19.  Collectively, this funding is referred to as the “CARES Act Provider Relief Fund.” The Department of Health and Human Services (HHS) began the disbursement of the first $30 billion tranche of the CARES Act Provider Relief Funding on April 10, 2020, with full disbursement of this tranche being completed by April 17, 2020.  The American Ambulance Association has issued a Frequently Asked Question that provides additional details on how the payments under this first tranche were calculated, as well as the terms and conditions that are applicable to this disbursement. On...

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NREMT Statement to National Governors Association

COVID-19 Impact on Essential Critical Infrastructure Workers and Requested URGENT Action of Governors to Ensure Continuity of the Supply of Certified Emergency Medical Services Professionals (EMTs & Paramedics) and other Essential Critical Infrastructure Workers. Statement by the National Registry of Emergency Medical Technicians. Download PDF Problem: The national COVID-19 pandemic containment efforts inadvertently impact a vital component of the licensure pathway for Essential Critical Infrastructure Workers like emergency medical services (EMS) responders (EMTs and paramedics) and many other health professions. Without immediate intervention, thousands of professionals – prepared and scheduled to take their final certification exams – could be prohibited from responding to the national public health crisis. Facts bearing on the problem: • Essential Critical Infrastructure Workers like EMTs, Paramedics, and other health professionals – in the interest of public safety – are required to take certification or licensure examinations prior to state licensure. For over 70 health professions, these examinations are administered by Pearson VUE in either a Pearson VUE owned facility (PPC) or its network of independent third-party test centers (PVTCs). • During the week of March 9th, most colleges and universities in the United States closed; consequently, this closed many PVTCs co-located on these campuses where...

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CMS NEWS: Trump Administration Launches New Healthcare Toolkit

Trump Administration Launches New Toolkit to Help States Navigate COVID-19 Pre-Hospital/Emergency Medical Services (EMS) Resources At President Trump’s direction, the Centers for Medicare & Medicaid Services (CMS) and the Assistant Secretary of Preparedness and Response (ASPR) released a new toolkit to help state and local healthcare decision-makers maximize workforce flexibilities when confronting 2019 Novel Coronavirus (COVID-19) in their communities. This toolkit includes a full suite of available resources to maximize responsiveness based on state and local needs, building on President Trump’s commitment to a COVID-19 response that is locally executed, state-managed, and federally supported. This work was developed by the Healthcare Resilience Task Force as part of the unified government’s response to COVID-19. This Topic Collection focuses on plans, tools, templates, and other immediately implementable resources to help with COVID-19 preparedness, response, recovery, and mitigation efforts, focusing on pre-hospital and emergency medical services (EMS) settings, including public safety answering points (PSAPs). Please refer to CDC’s Coronavirus Disease 2019 webpage for the most up-to-date clinical guidance on COVID19 outbreak management. If you have COVID-19 promising practices, plans, tools, or templates to share with your peers, please visit the ASPR TRACIE Information Exchange COVID-19 Information Sharing Page (registration required) and place your resources under the relevant...

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FAQs – HHS CARES Act Provider Relief Funding

Frequently Asked Questions (FAQs) related to HHS CARES Act Provider Relief Funding By Brian S. Werfel, Esq. In March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).  As part of that Act, Congress allocated $100 billion to the creation of a “CARES Act Provider Relief Fund,” which will be used to support hospitals and other healthcare providers on the front lines of the nation’s coronavirus response.  These funds will be used to fund healthcare-related expenses or to offset lost revenue attributable to COVID-10.  These funds will also be used to ensure that uninsured Americans have access to testing a treatment for COVID-19.  Collectively, this funding is referred to as the “CARES Act Provider Relief Fund.” On April 9, 2020, the Department of Health and Human Services (HHS) began the disbursement of the first $30 billion of this provider relief funding.  This disbursement was made to all healthcare providers and suppliers that were enrolled in the Medicare Program, and who received Medicare Fee-for-Service reimbursements during Calendar Year 2019.  For most ambulance providers and suppliers, these relief funds were automatically deposited into their bank accounts. In this Frequently Asked Question (FAQ), the AAA...

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Supplemental Funding for Emergency Medical Services

COVID-19: Supplemental Funding for Emergency Medical Services Developed by the Healthcare Resilience Task Force Emergency Medical Services (EMS) Prehospital Team. Download PDF 1. Purpose: This paper outlines two supplemental funding options for Emergency Medical Services (EMS) agencies affected by the COVID-19 pandemic. 2. Scope: This information applies to private non-profit organizations as well as for-profit EMS agencies. This guidance does not apply to government-owned and operated EMS agencies. 3. Overview of Existing Supplemental Funding Opportunities: a. Stafford Act Emergency and/or Major Disaster Declaration (Stafford Act): Emergency protective measures to save lives and protect public health (including emergency medical care and transport) are eligible for reimbursement under the Federal Emergency Management Agency’s (FEMA) Public Assistance program. State, territorial, tribal, and local government entities and certain private non-profit organizations are eligible to apply for Public Assistance. FEMA assistance will be provided at a 75 percent federal cost-share and may not duplicate assistance provided by the U.S. Department of Health and Human Services or other federal agencies. b. Coronavirus Aid, Relief, and Economic Security Act (CARES Act): The Paycheck Protection Program is a loan program administered by the U.S. Small Business Administration (SBA) to incentivize small businesses to keep workers on the payroll....

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CISA Releases Version 3.0 of the Essential Critical Infrastructure Workers List

Private Sector Update Created and distributed by the U.S. Department of Homeland Security Private Sector Office private.sector@dhs.gov April 17, 2020 The Cybersecurity and Infrastructure Security Agency (CISA) has released Version 3.0 of the Essential Critical Infrastructure Workers list. Version 3.0 provides clarity around a range of positions needed to support the critical infrastructure functions laid out in the original guidance and Version 2.0. This iteration includes a reorganization of the section around Healthcare and Public Health and more detail to clarify essential workers; emphasis for Emergency Medical Services workers; and adds lawyers and legal aid workers. Also included is language focused on sustained access and freedom of movement; a reference to the CDC guidance on safety for critical infrastructure workers; and a statement saying sick employees should avoid the workplace and the workforce. In worker categories, all references to “employees” or “contractors” have been changed to “workers.” Other additions include a reference to the USCG Marine Safety Information Bulletin on essential maritime workers; clarified language including vehicle manufacture; and many other small changes to clarify language. CISA issued initial guidance on Essential Critical Infrastructure Workers on March 19, which was developed to help state, local, tribal, and territorial authorities as...

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911 and Emergency Medical Services (EMS) Algorithms

911 and Emergency Medical Services (EMS) Algorithms Developed by the Healthcare Resilience Task Force Emergency Medical Services (EMS) Prehospital Team. Download PDF Attached, please find the latest document released by the Health Systems Resiliency Task Force.  Please use the communication mechanisms at your disposal to share this information with your members, constituents and clients.  All Task Force documents will also be posted on EMS.gov and/or 911.gov (as appropriate).  The NHTSA created these two portals for COVID Resources and will continue to update them three times a week, with new links and documents containing information on a variety of COVID-related topics.  You will find COVID resources here on EMS.gov, and here on 911.gov....

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HealthAffairs | Ambulance Balance Billing

HealthAffairs is a  subscription-based publication, so a paid subscription is required to view the full article. The abstract is reproduced below. Most Patients Undergoing Ground And Air Ambulance Transportation Receive Sizable Out-Of-Network Bills Karan R. Chhabra, Keegan McGuire, Kyle H. Sheetz, John W. Scott, Ushapoorna Nuliyalu, and Andrew M. Ryan ABSTRACT “Surprise” out-of-network bills have come under close scrutiny, and while ambulance transportation is known to be a large component of the problem, its impact is poorly understood. We measured the prevalence and financial impact of out-of-network billing in ground and air ambulance transportation. For members of a large national insurance plan in 2013–17, 71 percent of all ambulance rides involved potential surprise bills. For both ground and air ambulances, out-of-network charges were substantially greater than in-network prices, resulting in median potential surprise bills of $450 for ground transportation and $21,698 for air transportation. Though out-of-network air ambulance bills were larger, out-of-network ground ambulance bills were more common, with an aggregate impact of $129 million per year. Out-of-network air ambulance bills averaged $91 million per year, rising from $41 million in 2013 to $143 million in 2017. Federal proposals to limit surprise out-of-network billing should incorporate protections for patients undergoing ground or air ambulance transportation.