Paycheck Protection Program Funding Update

The Department of Treasury has announced that the $350 billion appropriated under the CARES Act for the Paycheck Protection Program has been exhausted. However, Congressional leaders are currently negotiating an economic stimulus package to act as a bridge between the CARES Act and the next comprehensive package stimulus package. A core provision of the bridge package is an allocation of an additional $250 billion for the Paycheck Protection Program. If your operation is in the process or plans to apply for a loan under the Paycheck Protection Program, you should move forward with your efforts. The AAA is advocating that the bridge package or next comprehensive package include more funding for ambulance services.

Considerations for State Emergency Medical Service Offices in Response to COVID-19

Considerations for State Emergency Medical Service Offices in Response to COVID-19 Developed by the Healthcare Resilience Task Force Emergency Medical Services (EMS) Prehospital Team. Download PDF Integration of Emergency Medical Services (EMS) into the state emergency management structure Ensure that the state EMS Office, including the state EMS medical director, is represented in, or has…

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Public Service Answering Points (PSAPs)/Emergency Communications Centers (ECCs) Call Screening

Public Service Answering Points (PSAPs)/Emergency Communications Centers (ECCs) Call Screening Document Developed by the Healthcare Resilience Task Force Emergency Medical Services (EMS) Prehospital Team. Download PDF This document is intended to provide procedural guidance to Public Safety Answering Points (PSAPs) and Emergency Medical Service (EMS) agencies on practices that could result in improved call screening and…

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CMS: Medical Necessity & Patient Signature Requirements During COVID-19

CMS Clarifies Medicare Requirements Related to Medical Necessity and the Patient Signature Requirement during Current National State of Emergency By Brian S. Werfel, Esq. On April 9, 2020, CMS updated its Frequently Asked Questions (FAQs) for billing Medicare Fee-For-Service Claims during the current national state of emergency.  This document includes guidance for numerous industry types,…

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Hotline to Check Status of CARES Direct Deposit

If you have not yet received your CARES Act direct deposit as described here, there is now a hotline to check the status.   Please call 866-569-3522 and have your tax ID# and the name of your ambulance service as registered with PECOS. According to HHS, all Medicare providers and suppliers should receive their deposit by April 17.

Thank you to AAA Payment Reform Chair Asbel Montes for sharing this information!

2% Payment Adjustment Suspended (Sequestration)

Medicare FFS Claims: 2% Payment Adjustment Suspended (Sequestration)

Section 3709 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act temporarily suspends the 2% payment adjustment currently applied to all Medicare Fee-For-Service (FFS) claims due to sequestration. The suspension is effective for claims with dates of service from May 1 through December 31, 2020.

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NASEMSO 2020 National EMS Assessment Released!

The National Association of State EMS Officials (NASEMSO) has released its 2020 EMS Assessment, updating the 2011 report. This report  provides unparalleled insights into the EMS systems that  provide mobile healthcare across our nation. We highly recommend that you download the full report at  www.nasemso.org/2020-assessment.

(Falls Church, Va.) In the midst of the COVID-19 pandemic and applause for first responders in the United States, the National Association of State Emergency Medical Services Officials (NASEMSO) has released the 2020 National EMS Assessment updating the 2011 assessment. The 2020 assessment provides a comprehensive accounting by state/territory of the numbers and types of all 911 ambulance services and emergency medical services (EMS) professionals.

The 2020 National EMS Assessment is the first set of documentation about these critical emergency medical response personnel and agencies to be published in nearly 20 years. Every year in times of disasters, disease outbreaks and daily medical emergencies, such as heart attacks and car crashes, out-of-hospital emergency medical care systems make life-and-death differences in the lives of millions of Americans. EMS systems are the safety net for hospital emergency departments and public health as the front lines of response to 911 calls. Additionally, responders place themselves in high risk situations on a daily basis, as well as during communicable disease outbreaks and pandemics.

Data collection for this assessment was completed in 2019 by NASEMSO members, who are the staff of the state agencies that license America’s critical EMS personnel and agencies. State EMS offices protect the public by regulating the human and organizational components of EMS systems across the United States, as well as executing their legislative mandates to implement and improve systems of care for time-sensitive emergencies in order to offer every patient an opportunity for survival and optimal outcomes. The assessment provides the following key findings:

  • More than 18,200 local EMS agencies respond to 911 calls for medical emergencies and injuries, utilizing nearly 73,500 ground vehicles such as ambulances and fire engines.

  • Local EMS agencies respond to nearly 28.5 million 911 dispatches every year in 41 states.

  • More than 750 services are licensed by state EMS offices to fly patients, using helicopters and fixed-wing aircraft to provide rapid transportation to critical care.

  • More than 1.03 million personnel are licensed as emergency medical technicians, paramedics, and other levels of EMS patient care capability within all 50 states, the District of Columbia, Puerto Rico and American Samoa.

  • More than 9,300 physicians serve as local EMS Medical Directors, assuring that contemporary and quality care is provided to patients.

  • Sixty percent of 53 state EMS offices participated or expect to participate in mass casualty exercises involving a biological threat during the 18-month evaluation period.

  • The report is available from NASEMSO at www.nasemso.org/2020-assessment.

HHS Announces Release of Initial Tranche of CARES Act Provider Relief Funding

On 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…

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COVID-19 Relief Payments Begin Today

AAA ADVOCATES FOR COVID-19 RELIEF FOR AMBULANCE SERVICES COVID-19 Relief Payments Begin Today Beginning today, ambulance service suppliers and providers should start automatically receiving an allocation of payments from the Public Health and Social Emergency Fund. According to the Department of Health and Human Services (HHS), an initial distribution of $30 billion of the funds…

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CARES Act Provider Relief Fund

President Trump is providing support to healthcare providers fighting the COVID-19 pandemic. On March 27, 2020, the President signed the bipartisan CARES legislation that provides $100 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding will be used to support healthcare-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get testing and treatment for COVID-19.

Immediate infusion of $30 billion into healthcare system

Recognizing the importance of delivering funds in a fast and transparent manner, $30 billion is being distributed immediately – with payments arriving via direct deposit beginning April 10, 2020 – to eligible providers throughout the American healthcare system. These are payments, not loans, to healthcare providers, and will not need to be repaid.

Who is eligible for initial $30 billion

  • All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution.
  • Payments to practices that are part of larger medical groups will be sent to the group’s central billing office.
    • All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN).
  • As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
  • This quick dispersal of funds will provide relief to both providers in areas heavily impacted by the COVID-19 pandemic and those providers who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services.

How are payment distributions determined

  • Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.
  • A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization’s revenue management system.
  • As an example: A community hospital billed Medicare FFS $121 million in 2019. To determine how much they would receive, use this equation:
    • $121,000,000/$484,000,000,000 x $30,000,000,000 = $7,500,000

What to do if you are an eligible provider

  • HHS has partnered with UnitedHealth Group (UHG) to provide rapid payment to providers eligible for the distribution of the initial $30 billion in funds.
  • Providers will be paid via Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS).
    • The automatic payments will come to providers via Optum Bank with “HHSPAYMENT” as the payment description.
    • Providers who normally receive a paper check for reimbursement from CMS, will receive a paper check in the mail for this payment as well, within the next few weeks.
  • Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020, and will be linked on this page.
  • HHS’ payment of this initial tranche of funds is conditioned on the healthcare provider’s acceptance of the Terms and Conditions – PDF, which acceptance must occur within 30 days of receipt of payment.  If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed.  Appropriate contact information will be provided soon.

Is this different than the CMS Accelerated and Advance Payment Program?

Yes. The CMS Accelerated and Advance Payment Program has delivered billions of dollars to healthcare providers to help ensure providers and suppliers have the resources needed to combat the pandemic. The CMS accelerated and advance payments are a loan that providers must pay back. For more information from CMS, click here.

How this applies to different types of providers

All relief payments are being made to providers and according to their tax identification number (TIN). For example:

  • Large Organizations and Health Systems: Large Organizations will receive relief payments for each of their billing TINs that bill Medicare. Each organization should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Employed Physicians: Employed physicians should not expect to receive an individual payment directly. The employer organization will receive the relief payment as the billing organization.
  • Physicians in a Group Practice: Individual physicians and providers in a group practice are unlikely to receive individual payments directly, as the group practice will receive the relief fund payment as the billing organization. Providers should look to the part of their organization that bills Medicare to identify details on Medicare payments for 2019 or to identify the accounts where they should expect relief payments.
  • Solo Practitioners: Solo practitioners who bill Medicare will receive a payment under the TIN used to bill Medicare.

Priorities for the remaining $70 billion

The Administration is working rapidly on targeted distributions that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

Ensuring Americans are not surprised by bills for COVID-19 medical expenses

The Trump Administration is committed to ensuring that Americans are protected against financial obstacles that might prevent them from getting the testing and treatment they need from COVID-19.

  • As announced in early April, a portion of the $100 billion Provider Relief Fund will be used to reimburse healthcare providers, at Medicare rates, for COVID-related treatment of the uninsured.
    • As a condition, providers are obligated to abstain from “balance billing” any patient for COVID-related treatment.
  • The Families First Coronavirus Response Act requires private insurers to cover an insurance plan member’s cost-sharing payments for COVID-19 testing.
  • President Trump has also secured commitments from private insurers, including Humana, Cigna, UnitedHealth Group, and the Blue Cross Blue Shield system to waive cost-sharing payments for treatment related to COVID-19 for plan members.
Content created by Assistant Secretary for Public Affairs (ASPA)
Content last reviewed on April 9, 2020

COVID-19 Aid Programs Comparison

The recent Coronavirus Aid, Relief, and Economic Security Act (CARES Act) brings much-needed financial assistance to ambulance services and their employees. The chart below is designed to assist EMS leaders in determining which programs are best for you. Download the Chart as a PDF…

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Paycheck Protection Program Loans Summary

Summary of Loans Under Paycheck Protection Program (Section 1102) Download PDF Overview Section 1102 provides $349 billion for expedited individual loans up to $10 million through approved lenders that are guaranteed 100% by the U.S. government. The loan proceeds can be used to cover payroll support (such as employee salaries, paid sick or medical leave,…

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5 Steps to an Emergency Small Business Coronavirus Loan

Download PDF from Akin Gump – Five Steps to an SBA PPP Loan Step 1. Does my business qualify? Were you in business on February 15, 2020? Does your business have at least one but no more than 500 employees or do you meet the applicable SBA size standards for your industry? Have you faced…

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Summary of Financial Relief Provisions Under the CARES Act

AAA Operations & Human Resources Consultant Scott Moore, Esq has developed a summary of financial relief provisions from the recent CARES Act. The resource will help your organization evaluate in which programs it may qualify to participate. Download the CARES Act Financial Relief Comparison Download the Paycheck Protection Program Calculator…

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Treasury and SBA Begin Unprecedented Public-Private Mobilization Effort to Distribute Funds

US Treasury Press Release:            March 31, 2020

Contact:                     Treasury Public Affairs, (202) 622-2960

With $349 Billion in Emergency Small Business Capital Cleared, Treasury and SBA Begin Unprecedented Public-Private Mobilization Effort to Distribute Funds

WASHINGTON – Following President Trump’s signing of the historic Coronavirus Aid, Relief, and Economic Security (CARES) Act, SBA Administrator Jovita Carranza and Treasury Secretary Steven T. Mnuchin today announced that the SBA and Treasury Department have initiated a robust mobilization effort of banks and other lending institutions to provide small businesses with the capital they need.

The CARES Act establishes a new $349 billion Paycheck Protection Program. The Program will provide much-needed relief to millions of small businesses so they can sustain their businesses and keep their workers employed.

“This legislation provides small business job retention loans to provide eight weeks of payroll and certain overhead to keep workers employed,” said Secretary Mnuchin. “Treasury and the Small Business Administration expect to have this program up and running by April 3rd so that businesses can go to a participating SBA 7(a) lender, bank, or credit union, apply for a loan, and be approved on the same day.  The loans will be forgiven as long as the funds are used to keep employees on the payroll and for certain other expenses.”

“This unprecedented public-private partnership is going to assist small businesses with accessing capital quickly. Our goal is to position lenders as the single point-of-contact for small businesses – the application, loan processing, and disbursement of funds will all be administered at the community level,” said Administrator Carranza. “Speed is the operative word; applications for the emergency capital can begin as early as this week, with lenders using their own systems and processes to make these loans. We remain committed to supporting our nation’s more than 30 million small businesses and their employees, so that they can continue to be the fuel for our nation’s economic engine.”

The new loan program will help small businesses with their payroll and other business operating expenses. It will provide critical capital to businesses without collateral requirements, personal guarantees, or SBA fees – all with a 100% guarantee from SBA. All loan payments will be deferred for six months. Most importantly, the SBA will forgive the portion of the loan proceeds that are used to cover the first eight weeks of payroll costs, rent, utilities, and mortgage interest.

The Paycheck Protection Program is specifically designed to help small businesses keep their workforce employed. Visit SBA.gov/Coronavirus for more information on the Paycheck Protection Program.

  • The new loan program will be available retroactive from Feb. 15, 2020, so employers can rehire their recently laid-off employees through June 30, 2020.

Loan Terms & Conditions

  • Eligible businesses: All businesses, including non-profits, Veterans organizations, Tribal concerns, sole proprietorships, self-employed individuals, and independent contractors, with 500 or fewer employees, or no greater than the number of employees set by the SBA as the size standard for certain industries
  • Maximum loan amount up to $10 million
  • Loan forgiveness if proceeds used for payroll costs and other designated business operating expenses in the 8 weeks following the date of loan origination (due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs)
  • All loans under this program will have the following identical features:
    • Interest rate of 0.5%
    • Maturity of 2 years
    • First payment deferred for six months
    • 100% guarantee by SBA
    • No collateral
    • No personal guarantees
    • No borrower or lender fees payable to SBA

Visit treasury.gov/cares for more information on SBA’s assistance to small businesses.

SBA | Economic Injury Disaster Loans

The US Small Business Administration’s Economic Injury Disaster Loan program provides small businesses with working capital loans of up to $2 million that can provide vital economic support to small businesses to help overcome the temporary loss of revenue they are experiencing. In response to the Coronavirus (COVID-19) pandemic, small business owners in all U.S. states, Washington D.C., and territories are eligible to apply.

 

Summary of March 28, 2019 Ambulance ODF

The Centers for Medicare and Medicaid Services (CMS) held its latest Open Door Forum on Wednesday, March 28, 2019.  As with past Open Door Forums, CMS started the call with the following announcements:

  1. Ambulance Cost Data Collection – CMS reminded the industry that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, requires CMS to create a new cost data collection system by December 31, 2019.
  2. Emergency Triage, Treat, and Transport Model – A representative from the Innovation Center within CMS provided an overview of the “Emergency Triage, Treat, and Transport Model” or “ET3.” This is a 5-year pilot program intended to provide ambulance providers with greater flexibility to handle low-acuity 911 calls, by providing Medicare payment for: (a) ambulance transportation to alternative treatment destinations and (b) treatment at the scene. The CMS representative indicated that CMS is in possession of data that suggests that 16% of emergency ambulance transports to a hospital emergency department could have been resolved by transporting the patient to an alternative treatment site, e.g., an urgent care center. CMS estimates that had all of these patients elected to receive care in the lower-acuity setting, it would have saved the Medicare Program approximately $560 million each year. With respect to the operation of the model itself, CMS essentially repeated the information that had been previously provided on its webinars. You can view the AAA Member Advisory on the ET3 Model by clicking here.
  3. Ambulance Inflation Factor – CMS reiterated that the 2019 Ambulance Inflation Factor is 2.3%.

Following the announcements, CMS moved into a Question & Answer period. The majority of the questions related to the ET3 pilot program. As is typical, many questions were not answered on the call; instead, CMS asked the individual to submit their question in writing. However, the following questions were answered on the call:

  1. Payment Rates under ET3 – CMS was asked whether the BLS base rate payment would be the BLS emergency base rate. It was not clear that the CMS representative fully understood the question, although she indicated that it would.
  2. Eligibility for Government Agencies – CMS was asked whether governmental agencies that operate 911 centers would submit applications to participate as part of the RFA process in the Summer of 2019. CMS responded that governmental agencies that operate 911 centers would not submit RFAs, but would rather wait for the Notice of Funding Opportunity (NOFO), which will be issued after the ambulance providers and suppliers are selected for participation (expected to be the late Fall/Winter of 2019). CMS further confirmed that if the governmental agency also operated its own ambulance service that it would be eligible to apply for both aspects of the ET3 Model.
  3. Limit on Ambulance Providers – CMS was asked whether it would cap the number of ambulance providers and suppliers selected to participate in the program. CMS responded that, at the present time, it has no intent to cap the number of participating ambulance providers and suppliers at any specific number.
  4. Return Transports from Alternative Treatment Destinations – CMS was asked whether the model would provide for ambulance payment for the return transport after a patient was transported to an alternative treatment site. CMS indicated that the model does not provide for payment for the return transport.
  5. Definition of “Telehealth” – CMS confirmed that the model will use the same definition of “telehealth” used in other areas of the Medicare Program. CMS further confirmed that telehealth encounters require both audio and video connections.
  6. Approval of Alternative Treatment Sites – CMS confirmed that state and local regulatory agencies would have final approval over acceptable alternative treatment sites.
  7. Qualified Health Care Practitioner – CMS confirmed that a “qualified health care practitioner” would be an individually enrolled Medicare practitioner, which includes physicians and nurse practitioners. In some instances, it can also include physician’s assistants. CMS confirmed that the definition would not include registered nurses or advance scope paramedics.
  8. NOFO Funding – CMS indicated that, at the present time, it is not prepared to release additional details on the nature or size of the funding opportunities available to governmental agencies and their designees that operate or have authority over 911 centers.
  9. Medicare Advantage and Other Payers – CMS confirmed that the ET3 Model applies only to Medicare beneficiaries enrolled in FFS Medicare. It does not apply to Medicare Advantage enrollees, Medicaid recipients, etc.

Questions? Email Brian at bwerfel@aol.com

Narberth Ambulance Overcomes Major Hurdles In Its Billing System

Pennsylvania EMS Provider Achieves Major Billing Milestones Through Payor Logic Partnership and ESO Integration The Volunteer Medical Service Corps of Narberth was established in 1944 by residents of Narberth Borough, a suburb of Philadelphia, to provide transportation and first aid for soldiers returning from World War II via Philadelphia’s ports. The organization, now known as…

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IRS Proposed Rule on 199A Passthrough Deduction

The 199A passthrough business deduction was created under the Tax Cuts and Jobs Act that was signed into law on December 22, 2017. The creation of the 199A section within this legislation has since created many questions and needed clarifications.

On August 8, 2018, the Internal Revenue Service (IRS) issued proposed regulations that provide guidance that further clarifies which passthrough businesses are able to take advantage of this deduction as well as how taxpayers and tax professionals alike can navigate this new deduction. Section 199A allows domestic businesses operated as a sole proprietorship or through a partnership, Limited Liability Company (LLC), S corporation, trust, or estate to deduct up to 20% of qualified business income from tax years between 2018 and 2025.

Those who have taxable income of $315,000 or less for joint filers and $157,500 or less for single filers will now be able to take advantage of the deduction. Those who exceed these taxable incomes will be subject to certain limitations. These limitations could include the taxpayer’s taxable income and limitation by 50% of W-2 wages. These regulations clarify that individuals and certain trusts and estates may be able to take a deduction of up to 20 percent of their combined qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership (PTP) income, including qualified REIT dividends and qualified PTP income earned through passthrough entities.

The 199A deduction can be used at the partner or shareholder level and takes into account the shareholder’s allocable share of items of qualified income and loss, unadjusted basis of the partnership or S-corporation, and W-2 wages. This proposed regulation reinforces that income earned through a C-corporation is not entitled to the deduction. Those who are in favor of this deduction maintain that it will help to reduce the tax rate on pass through and small businesses in order to provide increased parity between pass throughs and C-corporations.

The IRS released guidance with the proposed regulation that includes methods to calculate W-2 wages for purposes of section 199A. Additionally, the IRS published a FAQ page that can also be used as a resource in navigating this new deduction and can be found here.

There is a 45-day comment period where comments can be submitted to the IRS. This comment period is a great opportunity for AAA members who could benefit from the deduction to weigh in, especially where the proposed rule specifically seeks comment in the area of whether a pass-through entity should be able to aggregate its trades or businesses and whether there are proper times to include Section 707(a) payment in qualified business income. A hearing was scheduled by the Department of Treasury on the 199A regulations that will be held on October 16, 2018.