CMS Publishes Two New Reports on GADCS Website
Dear Ground Ambulance Providers and Suppliers,
We wanted you to be aware that we posted 2 reports on our Medicare Ground Ambulance Data Collection System website under Reports: |
Dear Ground Ambulance Providers and Suppliers,
We wanted you to be aware that we posted 2 reports on our Medicare Ground Ambulance Data Collection System website under Reports: |
The letter to the editor below was submitted to The Guardian on July 23, following the July 21 publication of the article referenced.
To the Editor of The Guardian,
On July 21, The Guardian published Jessica Glenza’s “Plan to end exorbitant ‘surprise’ ambulance bills heads to Congress.” The inflammatory title and lack of context do no justice to the years of bipartisan collaborative effort leading to the forthcoming report to Congress. As a member of the Advisory Committee on Ground Ambulance and Patient Billing (GAPB) and Immediate Past President of the American Ambulance Association, I believe it is critical to set the record straight.
It is essential to understand that EMS directly bills patients instead of insurers only as a last resort. Sadly, as a frequent entry point to healthcare, EMS often faces the unenviable task of educating people about their limited insurance coverage or high deductibles, both of which are out of our control. As mobile healthcare is entirely decentralized in the United States, it is often unfeasible for small or volunteer-staffed ambulance services to negotiate sustainable in-network rates with dozens of insurance plans. The GAPB Advisory Committee’s recommendations seek to remedy this foundational disconnect between patients, EMS providers, and health plans.
The article notes that some EMS providers are owned by private equity, but overlooks that the vast majority of ambulance services in the United States are small, often conducting only a few dozen patient transports per day. These community-based services—some of which are the sole healthcare provider for miles—face skyrocketing costs for wages, fuel, and medical supplies that threaten their ability to keep their doors open. The collaborative work of the GAPB Advisory Committee sought to address these challenges by proposing recommendations that, if adopted by Congress, would help alleviate these financial pressures while also enhancing patient protection from surprise insurance denials.
The article implies that Patricia Kelmar was the only representative of the public interest on the panel. In fact, another Committee participant was explicitly appointed to represent patient advocacy groups, and as healthcare providers, EMS professionals and physicians consistently advocate for our patients’ well-being. The committee’s composition, as established by Congress within the No Surprises Act, was intentionally diverse and included stakeholders ranging from physicians to elected officials to insurance providers to ensure balance.
Additionally, it is important to clarify that the Health Affairs research cited in the article does not provide data on actual balance bills received by patients. Rather, it roughly estimates only potential balance bills as calculated based on a flawed estimation process. Even if we were to accept Health Affairs estimates as fact, the average balance bill calculated according to their methods would be just a few hundred dollars. This is far from the sole and extreme outlier bill cited in the piece. This distinction is critical as it underscores the need for data-driven policy decisions based on real-world evidence rather than projections and one-off examples.
Finally, the piece misses entirely the largest challenge with the Committee’s recommendations and their potential adoption by Congress. Based on longstanding legal precedent, ERISA plans, which cover about half of Americans through their employers, would not be bound by any legislation drafted based on our report. In Washington state and elsewhere, innovative “opt-in” clauses enable ERISA plans to voluntarily comply with state regulation. We encourage this and hope to see it replicated throughout the nation.
People become first responders because they have a passion for caring for others, and our communities trust them to do just that—24/7. Our Committee’s report to Congress includes 14 key recommendations designed to improve transparency, ensure fair reimbursement rates, and ultimately protect patients by strengthening state and local control. If these recommendations are adopted, they will help remove patients from the middle of billing disputes, allowing EMS providers to focus on our primary mission: delivering life-saving and life-sustaining healthcare around the clock.
For a detailed understanding of our recommendations and the Committee’s work, I encourage reading the full GAPB Advisory Committee report when it becomes available later this summer.
Shawn Baird
Immediate Past President, American Ambulance Association
Member, Advisory Committee on Ground Ambulance and Patient Billing
Portland, Oregon
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orFrom the OSHA Website on June 4, 2024
NEW Update: The deadline for comment submission has been extended a second time to July 22, 2024.
The Emergency Response proposed rule is here!
OSHA is happy to announce that the Emergency Response proposed rule has been published in the Federal Register and is now available for viewing.
OSHA welcomes and encourages the submission of public comments in response to this proposed rule. To allow additional time for those individuals interested in creating and submitting a comment, OSHA will be further extending the window for comment submission. The comment period now ends on July 22, 2024.
Comments can be submitted to the Emergency Response Docket at https://www.regulations.gov/docket/OSHA-2007-0073.
OSHA will also be hosting a public hearing, the date of which has yet to be determined. To ensure access to the hearing for all interested members of the public, remote access will be provided.
Additional information on OSHA’s rulemaking process and how stakeholders can participate is available at https://www.osha.gov/laws-regs/rulemakingprocess.
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orThe next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, April 11, 2024
Start Time: 2:00pm-3:00pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
II. Announcements & Updates
1. Medicare Ground Ambulance Data Collection System (GADCS)
III. Open Q&A
**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
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This Open Door Forum is open to everyone, but if you are a member of the Press,
you may listen in but please refrain from asking questions during the Q & A portion of
the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank
you.
NEW and UPDATED Open Door Forum Participation Instructions:
This call will be a Zoom webinar with registration and login instructions below.
Register in advance for this webinar:
https://cms.zoomgov.com/webinar/register/WN_vfsU5LSKR3atiW9T_AhrDg
Meeting ID: 160 823 4591
Passcode: 200020
After registering, you will receive a confirmation email containing information about
joining the webinar. You may also add the webinar to your calendar using the dropdown arrow on the “Webinar Registration Approved” webpage after registering.’
Although the ODFs are now a Zoom webinar, we will only use the audio function, no need for cameras to be on.
For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/OpenDoorForums/.
Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. The webinar recording and transcript will be posted to: https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.
CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.
Yesterday was a proud day for EMS!
Thank you to Matt Zavadsky and Medstar Mobile Healthcare for developing this highlights clip from the recent House Ways & Means field hearing focused on emergency services.
Yesterday, Dr. @ed_racht of @AMR_social and former @NAEMT_ President @mattzavadsky provided testimony at a House Ways & Means field hearing on the challenges and opportunities facing #EMS. We appreciate the Committee’s time and attention! #SupportEMS #alwaysopen #NotJustaRide pic.twitter.com/5hKSJLGEd5
— American Ambulance Association (@amerambassoc) March 19, 2024
From the Centers for Medicare & Medicaid Services on March 9
The Centers for Medicare & Medicaid Services (CMS) is continuing to monitor and assess the impact that the cyberattack on UnitedHealth Group’s subsidiary Change Healthcare has had on all provider and supplier types. Today, CMS is announcing that, in addition to considering applications for accelerated payments for Medicare Part A providers, we will also be considering applications for advance payments for Part B suppliers.
Over the last few days, we have continued to meet with health plans, providers and suppliers to hear about their most pressing concerns. As announced previously, we have directed our Medicare Administrative Contractors (MACs) to expedite actions needed for providers and suppliers to change the clearinghouse they use and to accept paper claims if providers need to use that method. We will continue to respond to provider and supplier inquiries regarding MAC processes.
CMS also recognizes that many Medicaid providers are deeply affected by the impact of the cyberattack. We are continuing to work closely with States and are urging Medicaid managed care plans to make prospective payments to impacted providers, as well.
All MACs will provide public information on how to submit a request for a Medicare accelerated or advance payment on their websites as early as today, Saturday, March 9.
CMS looks forward to continuing to support the provider community during this difficult situation. All affected providers should reach out to health plans and other payers for assistance with the disruption. CMS has encouraged Medicare Advantage (MA) organizations to offer advance funding to providers affected by this cyberattack. The rules governing CMS’s payments to MA organizations and Part D sponsors remain unchanged. Please note that nothing in this statement speaks to the arrangements between MA organizations or Part D sponsors and their contracted providers or facilities.
For more information view the Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/change-healthcare/optum-payment-disruption-chopd-accelerated-payments-part-providers-and-advance
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AAA President Randy Strozyk will testify tomorrow, February 14, at 10:00 am (eastern) before the Health Subcommittee of the Energy and Commerce Committee of the U.S. House of Representatives. The hearing is on “Legislative Proposals To Support Patients And Caregivers” and Randy will speak to the SIREN Reauthorization Act (H.R. 4646), EMS for Children Reauthorization Act (H.R. 6960) and legislation to reauthorize the Traumatic Brain Injury program (H.R. 7208) and certain poison control programs (H.R. 7251).
The hearing will be live streamed online at https://youtu.be/Zy-4NCuheGM.
The hearing will provide the AAA and Randy with a platform to voice support for the EMS proposals on the agenda as well as raise the need for the Committee to address our Medicare ambulance add-on payments and the EMS workforce shortage. For a copy of Randy’s written testimony and other details of the hearing, please go to the Committee website for the hearing.
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orFrom EMS.gov on January 24, 2024
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Final rule modernizes the health care system and reduces patient and provider burden by streamlining the prior authorization process
As part of the Biden-Harris Administration’s ongoing commitment to increasing health data exchange and strengthening access to care, the Centers for Medicare & Medicaid Services (CMS) finalized the CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F) today. The rule sets requirements for Medicare Advantage (MA) organizations, Medicaid and the Children’s Health Insurance Program (CHIP) fee-for-service (FFS) programs, Medicaid managed care plans, CHIP managed care entities, and issuers of Qualified Health Plans (QHPs) offered on the Federally-Facilitated Exchanges (FFEs), (collectively “impacted payers”), to improve the electronic exchange of health information and prior authorization processes for medical items and services. Together, these policies will improve prior authorization processes and reduce burden on patients, providers, and payers, resulting in approximately $15 billion of estimated savings over ten years.
“When a doctor says a patient needs a procedure, it is essential that it happens in a timely manner,” said HHS Secretary Xavier Becerra. “Too many Americans are left in limbo, waiting for approval from their insurance company. Today the Biden-Harris Administration is announcing strong action that will shorten these wait times by streamlining and better digitizing the approval process.”
“CMS is committed to breaking down barriers in the health care system to make it easier for doctors and nurses to provide the care that people need to stay healthy,” said CMS Administrator Chiquita Brooks-LaSure. “Increasing efficiency and enabling health care data to flow freely and securely between patients, providers, and payers and streamlining prior authorization processes supports better health outcomes and a better health care experience for all.”
While prior authorization can help ensure medical care is necessary and appropriate, it can sometimes be an obstacle to necessary patient care when providers must navigate complex and widely varying payer requirements or face long waits for prior authorization decisions. This final rule establishes requirements for certain payers to streamline the prior authorization process and complements the Medicare Advantage requirements finalized in the Contract Year (CY) 2024 MA and Part D final rule, which add continuity of care requirements and reduce disruptions for beneficiaries. Beginning primarily in 2026, impacted payers (not including QHP issuers on the FFEs) will be required to send prior authorization decisions within 72 hours for expedited (i.e., urgent) requests and seven calendar days for standard (i.e., non-urgent) requests for medical items and services. For some payers, this new timeframe for standard requests cuts current decision timeframes in half. The rule also requires all impacted payers to include a specific reason for denying a prior authorization request, which will help facilitate resubmission of the request or an appeal when needed. Finally, impacted payers will be required to publicly report prior authorization metrics, similar to the metrics Medicare FFS already makes available.
The rule also requires impacted payers to implement a Health Level 7 (HL7®) Fast Healthcare Interoperability Resources (FHIR®) Prior Authorization application programming interface (API), which can be used to facilitate a more efficient electronic prior authorization process between providers and payers by automating the end-to-end prior authorization process. Medicare FFS has already implemented an electronic prior authorization API, demonstrating the efficiencies other payers could realize by implementing such an API. Together, these new requirements for the prior authorization process will reduce administrative burden on the healthcare workforce, empower clinicians to spend more time providing direct care to their patients, and prevent avoidable delays in care for patients.
In response to feedback received on multiple rules and extensive stakeholder outreach HHS will be announcing the use of enforcement discretion for the Health Insurance Portability and Accountability Act of 1996 (HIPAA) X12 278 prior authorization transaction standard to further promote efficiency in the prior authorization process. Covered entities that implement an all-FHIR-based Prior Authorization API pursuant to the CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F) who do not use the X12 278 standard as part of their API implementation will not be enforced against under HIPAA Administrative Simplification, thus allowing limited flexibility for covered entities to use a FHIR-only or FHIR and X12 combination API to meet the requirements of the CMS Interoperability and Prior Authorization final rule. Covered entities may also choose to make available an X12-only prior authorization transaction. HHS will continue to evaluate the HIPAA prior authorization transaction standards for future rulemaking.
CMS is also finalizing API requirements to increase health data exchange and foster a more efficient health care system for all. CMS values public input and considered the comments submitted by the public, including patients, providers, and payers, in finalizing the rule. Informed by these public comments, CMS is delaying the dates for compliance with the API policies from generally January 1, 2026, to January 1, 2027. In addition to the Prior Authorization API, beginning January 2027, impacted payers will be required to expand their current Patient Access API to include information about prior authorizations and to implement a Provider Access API that providers can use to retrieve their patients’ claims, encounter, clinical, and prior authorization data. Also informed by public comments on previous payer-to-payer data exchange policies, we are requiring impacted payers to exchange, with a patient’s permission, most of those same data using a Payer-to-Payer FHIR API when a patient moves between payers or has multiple concurrent payers.
Finally, the rule also adds a new Electronic Prior Authorization measure for eligible clinicians under the Merit-based Incentive Payment System (MIPS) Promoting Interoperability performance category and eligible hospitals and critical access hospitals (CAHs) in the Medicare Promoting Interoperability Program to report their use of payers’ Prior Authorization APIs to submit an electronic prior authorization request. Together, these policies will help to create a more efficient prior authorization process and support better access to health information and timely, high-quality care.
The final rule is available to review here: https://www.cms.gov/files/document/cms-0057-f.pdf.
The fact sheet for this final rule is available here: https://www.cms.gov/newsroom/fact-sheets/cms-interoperability-and-prior-authorization-final-rule-cms-0057-f.
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The US Fire Administration (USFA) and Fire Safety Research Institute (FSRI) have announced the commencement of a national engagement period for the National Emergency Response Information System (NERIS) Draft Data Framework. This period will end on January 19, 2024.
The EMS community is invited to offer feedback on the Draft Core NERIS Data Framework, which includes essential data schemas crucial for NERIS operations, designed to provide the EMS and fire community with the necessary data and tools for improved decision-making and enhanced incident preparedness. These schemas include:
Access the Draft NERIS Data Framework and submit feedback by January 19, 2024. To submit feedback, access the feedback submission form below after reviewing the Framework.
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For accessibility requests or further assistance, please contact NERIS@ul.org.
Request for Proposal
The American Ambulance Association (AAA) seeks proposals from qualified consulting firms to provide strategic services in the field of ambulance and emergency medical services. The selected firm will work collaboratively with the Association to identify opportunities, analyze state landscapes, develop policy recommendations, and manage the project efficiently.
Caring for People—First.
The American Ambulance Association safeguards the future of mobile healthcare through advocacy, thought leadership, and education. AAA advances sustainable EMS policy, empowering our members to serve their communities with high-quality on-demand healthcare. For more than 40 years, we have proudly represented those who care for people first. AAA’s 1500+ organizational members serve cities and counties in all 50 states.
The consulting firm shall provide the following services:
All deliverables should be received in calendar year 2024.
Proposals must include a detailed fee structure, including hourly rates for various personnel and any applicable prorated fees. A fixed total or capped amount is strongly preferred over uncapped “time and expenses” billing.
Proposals should be submitted by January 31, 2024 to info@ambulance.org with the subject line “State EMS Whitepaper Proposal.” Proposals should include a detailed approach to the scope of services, a proposed timeline for deliverable development, detailed qualifications of the team, and a clear fee structure. Submitters should include examples of past work of similar scope in the broader healthcare field.
Proposals will be evaluated based on the firm’s experience, approach to the project, team qualifications, and cost-effectiveness. Notification will be delivered by February 29, 2024.