HHS: Availability of Add’l $25.5 Billion in COVID-19 Provider Funding

HHS Announces the Availability of $25.5 Billion in COVID-19 Provider Funding

This morning the Department of Health and Human Services (HHS) announced that it will be making $25.5 billion in new funding available for healthcare providers affected by the COVID-19 pandemic. The funding, available through the Health Resources and Services Administration (HRSA) will include $8.5 billion in American Rescue Plan Act (ARPA) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic.

Getting additional financial relief for ground ambulance service providers who are still struggling from the lost revenue and increased expenditures resulting from being on the frontlines of responding to the pandemic has been a top priority for the AAA. The AAA along with the International Association of Fire Chiefs, International Association of Firefighters, National Associations of EMTs and National Volunteer Fire Association have continually pressed HHS to release the remaining funds. We strongly encourage all AAA members to submit an application regardless of whether you have applied for previous rounds of funding.

Consistent with the requirements included in the Coronavirus Response and Relief Supplemental Appropriations Act of 2020, PRF Phase 4 payments will be based on providers’ lost revenues and expenditures between July 1, 2020, and March 31, 2021 (Q3 – Q4 2020 and Q1 2021). The PRF Phase 4 will reimburse smaller providers, who tend to operate on thin margins and often serve vulnerable or isolated communities, for their lost revenues and COVID-19 expenses at a higher rate compared to larger providers. PRF Phase 4 will also include bonus payments for providers who serve Medicaid, CHIP, and/or Medicare patients, who tend to be lower- income and have greater and more complex medical needs. HRSA will price these bonus payments at the generally higher Medicare rates to ensure equity for those serving low-income children, pregnant women, people with disabilities, and seniors.

Consistent with the focus of the ARPA, HRSA will make ARPA rural payments to providers based on the amount of Medicaid, CHIP, and/or Medicare services they provide to patients who live in rural areas as defined by the HHS Federal Office of Rural Health Policy. As rural providers serve a disproportionate number of Medicaid and CHIP patients who often have disproportionately greater and more complex medical needs, many rural communities have been hit particularly hard by the pandemic. Accordingly, ARP rural payments will also generally be based on Medicare reimbursement rates.

In the announcement, HHS stated that it would “expedite and streamline” the application process and minimize administrative burdens, providers will apply for both programs in a single application. HRSA will use existing Medicaid, CHIP and Medicare claims data in calculating payments. The application portal will open on September 29, 2021. HHS has stated that to ensure that these provider relief funds are used for patient care, PRF recipients will be required to notify the HHS Secretary of any merger with, or acquisition of, another health care provider during the period in which they can use the payments. They have stated that providers who report a merger or acquisition may be more likely to be audited to confirm their funds were used for coronavirus-related costs.

To promote transparency in the PRF program, HHS also released detailed information about the methodology utilized to calculate PRF Phase 3 payments. Providers who believe their PRF Phase 3 payment was not calculated correctly according to this methodology will now have an opportunity to request a reconsideration. HHS announced that additional details on the PRF Phase 3 reconsideration process will be released at a later date.

In addition, many of you attended the PRF Reporting Q&A AAA webinar yesterday with Asbel Montes, Brian Werfel, and Scott Moore.  HHS has acknowledged the challenges facing many providers across the country due to recent natural disasters and the Delta variant, HHS announced a final 60-day grace period to help providers come into compliance with their PRF Reporting requirements if they fail to meet the deadline on September 30, 2021. While the deadlines to use funds and the Reporting Time Period will not change, HHS will not initiate collection activities or similar enforcement actions for non-compliant providers during this grace period.

Members can access more information about eligibility requirements, the documents and information providers will need to complete their application, and the application process for PRF Phase 4 and ARP Rural payments by visiting the HRSA website.

The combined application for American Rescue Plan rural funding and Provider Relief Fund Phase 4 will open on September 29, 2021.  Like we have done with the previous rounds of HHS funding, we encourage all ambulance service providers to submit an application for this Phase 4 funding.  If you have questions regarding this or any COVID-19 related questions, please contact hello@ambulance.org.

EMS Provider Comments Needed on the “Surprise Billing” Interim Final Rule

The Department of Health and Human Services, Department of Labor, and the U.S. Treasury Department (Departments) have issued an Interim Final Rule (IFR) on “surprise billing” that will take effect September 13, 2021.  However, the Departments are taking comments on the IFR.  While the Congress expressly excluded ground ambulance organizations from the statute that the IFR seeks to implement, the Departments have included a prohibition on balance billing for nonemergency ground ambulance transports that occur after a patient has been stabilized in a facility.

The Congress established an Advisory Committee to consider the best way to address balance billing in the context of ground ambulance services, and the Departments should wait to be advised by that group before subjecting nonemergency ground ambulance transports to the broader balancing billing prohibition.

It is important that the Departments hear from as many stakeholders as possible opposing this expansion of the law.  To help you develop a comment letter, we provided the following template that we ask you to tailor to your experience and organization.  Tailored letters will be of greater value to the Department as they consider the rules.  At a minimum, please customize the templated language to insert information about who you are and where you operate.

The must be submitted by September 7, 2021.

Submit Comments Quickly and Easily

EMS Balance Billing Quick Take—July 7, 2021

Webinar July 7, 2021 | 13:00–13:30 ET | Free to AAA Members
Speakers: Kathy Lester, Esq. & Asbel Montes

On July 1, CMS issued a proposed rule on Surprise Billing which applies to those providers and physicians identified in the No Surprises Act. This statute subjected ground ambulance suppliers to an HHS Advisory Committee process prior to any rulemaking addressing these services.

The consultants and staff of the American Ambulance Association are doing a deep dive into the 400+ page rule and evaluating its nuances. We continue to understand from our conversations that ground ambulances are not included and instead are subjected to the Advisory Committee.

The American Ambulance Association will soon provide a summary to members, and will address any confusion with the Administration. Join AAA for a quick take live webinar on July 7 at 13:00 ET to learn more!

Register Now

 

Medicare Ambulance Relief Bill introduced in Senate

Yesterday, Senators Catherine Cortez Masto (D-NV) and Susan Collins (R-ME) introduced the Protecting Access to Ground Ambulance Medical Services Act of 2021 (S. 2037). Senators Cortez Masto and Collins were joined by Senators Debbie Stabenow (D-MI), Bill Cassidy (R-LA), Patrick Leahy (D-VT) and Bernie Sanders (D-VT) as primary cosponsors and leads on the legislation.

S. 2037 is identical to H.R. 2454 by Representatives Terri Sewell (D-AL), Devin Nunes (R-CA), Peter Welch (D-VT) and Markwayne Mullin (R-OK) and would extend the temporary Medicare ground ambulance increases of 2% urban, 3% rural and the super rural bonus payment for five years. The increases are currently scheduled to expire on December 31, 2022. The five-year extension would allow for the increases to remain in place during the two-year delay on ambulance data collection due to the COVID-19 public health emergency, an analysis of the data by MedPAC and subsequent action by the Congress to reform the Medicare ambulance fee schedule.

The legislation would also help ensure that rural zip codes in large urban counties remain rural following geographical changes under the fee schedule as a result of the 2020 census data. The current definition using rural urban commuting areas (RUCA) in Goldsmith Modification areas would be modified for zip codes with 1,000 people or less per square mile would also be rural. Ground ambulance service providers and suppliers could also petition the Centers for Medicare and Medicaid Services (CMS) to make the argument that a specific zip code should be rural. It is vital that this provision be implemented before CMS makes changes from the 2020 census data which will likely occur in 2023.

The AAA has been leading the effort on the legislation with the support of the International Association of Fire Chiefs, International Association of Fire Fighters, National Association of EMTs, National Rural Health Association and the National Volunteer Fire Council.

The AAA will be launching a Call to Action shortly requesting AAA members to ask their Senators to cosponsor S. 2037, and reach out to their Representatives to cosponsor H.R. 2454 if they have not already done so.

We greatly appreciate the leadership of Senators Cortez Masto, Collins, Stabenow, Cassidy, Leahy, and Sanders on this vitally important legislation.

CNN | Rural ambulance crews are running out of money and volunteers

From CNN on May 22, 2021

Rural ambulance crews are running out of money and volunteers. In some places, the fallout could be nobody responding to a 911 call

America’s rural ambulance services, often sustained by volunteers, are fighting for their survival — a crisis hastened by the impact of Covid-19.

More than one-third of all rural EMS are in danger of closing, according to Alan Morgan, CEO of the National Rural Health Association. “The pandemic has further stretched the resources of our nation’s rural EMS.”

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HR2454 | Protecting Access to Ground Ambulance Medical Services Act of 2021

From Representative Terri Sewell

Rep. Sewell Introduces Legislation to Protect Access to Ground Ambulance Medical Services for Rural and Underserved Communities

Washington, D.C. – This Congress, U.S. Rep. Terri Sewell (AL-07), along with Reps. Devin Nunes (CA-22), Peter Welch (VT-AL), and Markwayne Mullin (OK-02), introduced H.R. 2454, the Protecting Access to Ground Ambulance Medical Services Act of 2021. The bill would ensure that ambulance service providers, including rural providers and those in underserved communities, are able to continue delivering quality critical first responder and health care services.

“When tragedy strikes and medical emergencies happen, we should feel confident that our first responders have the resources they need to deliver life-saving care,” said Rep. Sewell. “Unfortunately, inadequate Medicare reimbursement rates are putting a strain on ambulance service providers in the most vulnerable communities across the country and making it harder for them to care for our neighbors.”

“The problem is particularly severe for rural communities and has been worsened by the demands of the COVID-19 pandemic,” continued Sewell. “That is why I am proud to introduce the Protecting Access to Ground Ambulance Medical Services Act of 2021. This bill would permanently adjust Medicare reimbursement practices so that vital ambulance services remain vibrant and available to all Americans.”

“This bipartisan bill includes key reforms to ensure that rural Americans are not harmed by the delay in updating the Medicare ground ambulance fee schedule due to the COVID-19 pandemic,” said Rep. Nunes, Lead Republican Co-Sponsor. “Extending these temporary Medicare ground ambulance add-on payments for another five years and expanding coverage for those who live in zip codes with fewer than 1,000 people per square mile will keep ambulance costs affordable for Americans when they need ground ambulance transportation.”

“Rural ambulance services save lives and provide needed care in underserved areas every day,” said Rep. Peter Welch, Lead Democratic Co-Sponsor. “This bipartisan bill will ensure that patients in rural areas have access to critical ambulance services and that the providers of these services receive fair, consistent reimbursement for their important work. It’s time for Congress to pass this bill and give ambulance services the certainty they need to continue serving all Americans.”

“Ambulance services are critically important to rural Americans who may live close to an hour away from the nearest emergency room,” said Rep. Mullin, Lead Republican Co-Sponsor. “Providing this care literally means the difference between life and death for many people. As we continue to battle the closures of critical access hospitals across Oklahoma, ambulance services are more important now than ever before. We must ensure that rural Americans receive the care they need. I’m proud to join my colleagues in support of this bill which would enhance and increase resources for first responders in Oklahoma.”

Currently, ambulance service providers across the country are reimbursed by Medicare at rates below the cost of providing services, as determined by the Government Accountability Office (GAO). Consequently, providers rely on “add-on” payments to continue providing services. Add-on payments vary depending on whether a provider is located in an urban, rural, or “super rural” ZIP Code.

Congress has extended current add-on payment rates through December 31, 2022, and planned to review Medicare cost data in considering whether they should be made permanent. However, due to the upcoming ZIP Code reclassification which will occur following the 2020 Census, providers are faced with uncertainty regarding the future of these payments. Additionally, the COVID-19 pandemic forced the Centers for Medicare and Medicaid Services (CMS) to delay the first two rounds of data collection, compounding this uncertainty.

Background on the Protecting Access to Ground Ambulance Medical Services Act of 2021

H.R. 2454, the Protecting Access to Ground Ambulance Medical Services Act of 2021, would end the band-aid approach and make permanent adjustments to the reimbursement methodology for services in urban, rural, and “super rural” areas by building the temporary add-ons into the base rate fee. Specifically, it would extend the current temporary Medicare ground ambulance increases of 2% urban, 3% rural, and the super rural bonus payments for five years and would ensure that rural zip codes continue to be classified as rural following the ZIP Code reclassification.

These payments are vital to the financial viability of the ambulance community and have been extended numerous times on a bipartisan basis, most recently for 5 years. This five-year extension would allow a new data cost collection system time to be put into place and collect meaningful data following the delays caused by the COVID-19 pandemic.

“NRHA applauds Representative Terri Sewell for her leadership in working to preserve ground ambulance services in rural America. Throughout the pandemic ambulance services have provided critical first responder services in our most rural communities. Passing H.R. 2454, the Protecting Access to Ground Ambulance Medical Services Act of 2021, is critical to ensuring that these important services remain in their communities long after the public health emergency,” said Alan Morgan, Chief Executive Officer of the National Rural Health Association.

“The Alabama Rural Health Association lends its full support behind the ‘Protecting Access to Ground Ambulance Medical Services Act of 2021’ (H.R. 2454).  As rural EMS transportation is one of the greatest challenges for quality access to care in rural Alabama, support is greatly needed to reinforce the existing emergency transportation system.  With additional funding and flexibility created in the system, states like Alabama will have the ability to provide improved emergency transportation in critically rural and underserved areas and allow patients to receive the care that they need in a timely manner.  We are thankful for Rep. Sewell’s introduction of this language, and we encourage support for H.R. 2454,” said Ryan Kelly, Administrator of the Alabama Rural Health Association. 

The legislation is also supported by the following organizations:

  • American Ambulance Association (AAA)
  • International Association of Fire Chiefs (IAFC)
  • International Association of Fire Fighters (IAFF)
  • National Association of Emergency Medical Technicians (NAEMT)
  • National Volunteer Fire Council (NVFC)

H.R. 2454 can be found here.

Thank you to Representatives Rep. Terri Sewell, Congressman Devin Nunes, Peter Welch, and Congressman Markwayne Mullin…

May 6, 2021
Press Release

 

NYT | Rural Ambulance Crews Have Run Out of Money and Volunteers

From the New York Times by Ali Watkins on April 25, 2021

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Strained by pandemic-era budget cuts, stress and a lack of revenue, at least 10 ambulance companies in Wyoming are in danger of shuttering — some imminently.

Washakie County’s conundrum is reflective of a troubling trend in Wyoming and states like it: The ambulance crews that service much of rural America have run out of money and volunteers, a crisis exacerbated by the demands of the pandemic and a neglected, patchwork 911 system. The problem transcends geography: In rural, upstate New York, crews are struggling to pay bills. In Wisconsin, older volunteers are retiring, and no one is taking their place.

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Medicare Ambulance Relief Bill Introduced in House

Yesterday, Congresswoman Terri Sewell (D-AL) introduced the Protecting Access to Ground Ambulance Medical Services Act of 2021 (H.R. 2454). Congresswoman Sewell was joined by Congressmen Devin Nunes (R-CA), Peter Welch (D-VT) and Markwayne Mullin (R-OK) as primary cosponsors and leads on the legislation.

H.R. 2454 would extend the temporary Medicare ground ambulance increases of 2% urban, 3% rural and the super rural bonus payment for five years. The increases are currently scheduled to expire on December 31, 2022. The five-year extension would allow for the increases to remain in place during the two-year delay on ambulance data collection period due to the COVID-19 public health emergency.  It would also permit the cost collection program to move forward so that the statutorily mandated MedPAC analysis could be completed before the Congress would have to act to either further extend the add-ons or make them permanent through reforming the Medicare ambulance fee schedule.

The legislation would help address potential problems that rural zip codes in large urban counties could face as a result of the 2020 census data.  As we saw after the 2010 Census, the new Census data collection methodology resulted in geographical changes under the fee schedule that shifted rural ZIP codes to urban, despite there being no significant change in their population. The current definition using rural urban commuting areas (RUCA) in Goldsmith Modification areas would be modified to ensure ZIP codes with 1,000 people or less per square mile would remain rural. Ground ambulance service providers and suppliers could also petition the Centers for Medicare and Medicaid Services (CMS) to make the argument that a specific ZIP code should remain rural. It is vital that this provision be implemented before CMS makes changes from the 2020 Census data which will likely occur in 2023.

The AAA has been leading the effort on the legislation with the support of the Congressional Fire Services Institute, International Association of Fire Chiefs, International Association of Fire Fighters, National Association of EMTs and the National Volunteer Fire Council.

The AAA is working with champions of the effort in the Senate on introduction of a companion bill. We expect the bill to be introducing in the coming weeks.

The legislation is one of the policy issues being raised as part of EMS on the Hill Day and the AAA will be launching a Call To Action shortly requesting AAA members to ask their members of Congress to cosponsor the bill.

We greatly appreciate the leadership of Representatives Sewell, Nunes, Welch and Mullin on this vital issue.

CMS | Repayment of COVID-19 Accelerated & Advance Payments Began 3/30

Repayment of COVID-19 Accelerated and Advance Payments Began on March 30, 2021

CMS issued information about repayment of COVID-19 accelerated and advance payments. If you requested these payments, learn how and when we’ll recoup them:

  • Identify payments we recovered
  • Prepare your billing staff

More Information:

Joint Letter on Sequestration Delay

On March 15, the AAA, IAFC, IAFF, NFVC, NAEMT, and the Congressional Fire Services Institute sent a letter to congressional leaders in support of legislation (H.R. 1868) to extend the current moratorium on the 2% Medicare sequestration cut. The moratorium is currently scheduled to expire on March 31 and H.R. 1868 would extend the moratorium until December 31. Below is a copy of the letter.

This week, the House passed House Resolution 233 with the rules for debate and consideration of H.R. 1868. Congressmen Schneider (D-IL) and McKinley (R-WV) introduced H.R. 315 and Senators Sheehan (D-NH) and Collins (R-ME) introduced S. 748 which would extend the moratorium through the end of the public health emergency.

March 16, 2021

The Honorable Nancy Pelosi Speaker
U.S. House of Representatives
Washington, DC 20515

The Honorable Kevin McCarthy Minority Leader
U.S. House of Representatives
Washington, DC 20515

The Honorable Charles Schumer Majority Leader
United States Senate
Washington, DC 20510

The Honorable Mitch McConnell Minority Leader
United States Senate
Washington, DC 20510

Dear Speaker Pelosi, Majority Leader Schumer, Minority Leader McConnell and Minority Leader McCarthy:

Thank you for your continued support of front-line medical workers throughout the COVID-19 pandemic. Our paramedics, emergency medical technicians (EMTs) and firefighters, as well as the organizations that they serve, take on substantial risk every day to treat, transport and test potential COVID-19 patients. We write today to express our deep concern with the impending 2% Medicare sequestration cut scheduled to take effect on April 1, 2021.

The American Ambulance Association (AAA), International Association of Fire Chiefs (IAFC), International Association of Fire Fighters (IAFF), National Association of Emergency Medical Technicians (NAEMT), National Volunteer Fire Council (NVFC) along with the Congressional Fire Services Institute (CFSI) represent the providers of vital emergency and non-emergency ground ambulance services and the paramedics, EMTs and firefighters who deliver the direct medical care and transport for every community across the United States. We have all experienced the strain on our services, and need financial assistance and support as we remain the frontline responders to our nation’s coronavirus patients. The sequestered cuts, if implemented, would further strain the provision of these critical services.

Our costs of operating have increased exponentially in response to COVID-19, as we maintain full readiness to combat the pandemic and continue to provide 24-hour vital non-COVID-19- related services. Our costs for personal protective equipment (PPE), overtime pay, and other expenses directly related to COVID-19 remain high. At a time when we are facing considerable economic strain due to the COVID-19 pandemic, we respectfully urge Congress take action before April 1, 2021 to extend the 2% Medicare sequestration moratorium. We would like to voice our strong support for bipartisan legislation, H.R. 1868, to prevent the 2% sequester cut.

Our organizations greatly appreciate both the financial support provided through congressionally enacted COVID-19 relief legislation, as well as the recognition of the dangers of providing these critical services on a daily basis. However, the impact of the pandemic on our resources and services remains and the implementation of additional Medicare cuts at this time would be harmful to our members.

We thank you in advance for your consideration and helping ensure that EMS agencies and personnel have the resources they need to continue to respond to the COVID-19 pandemic and the funding to maintain the short and long-term viability of our operations.

Sincerely,

American Ambulance Association

Congressional Fire Services Institute

International Association of Fire Chiefs

International Association of Fire Fighters

National Association of Emergency Medical Technicians

National Volunteer Fire Council

CDC ACIP | Reccs for Allocating Initial COVID-19 Vaccines

From the CDC’s Morbidity and Mortality Weekly Report

The Advisory Committee on Immunization Practices’ Interim Recommendation for Allocating Initial Supplies of COVID-19 Vaccine — United States, 2020

What is already known about this topic?

Demand is expected to exceed supply during the first months of the national COVID-19 vaccination program.

What is added by this report?

The Advisory Committee on Immunization Practices (ACIP) recommended, as interim guidance, that both 1) health care personnel and 2) residents of long-term care facilities be offered COVID-19 vaccine in the initial phase of the vaccination program.

What are the implications for public health practice?

Federal, state, and local jurisdictions should use this guidance for COVID-19 vaccination program planning and implementation. ACIP will consider vaccine-specific recommendations and additional populations when a Food and Drug Administration–authorized vaccine is available.

Continue Reading

Dooling K, McClung N, Chamberland M, et al. The Advisory Committee on Immunization Practices’ Interim Recommendation for Allocating Initial Supplies of COVID-19 Vaccine — United States, 2020. MMWR Morb Mortal Wkly Rep. ePub: 3 December 2020. DOI: http://dx.doi.org/10.15585/mmwr.mm6949e1