Application Period Extended for FY 2021 Assistance to Firefighters Grant (AFG) Program

Please see the below notice from FEMA on the extension of the Assistance to Firefighter Grant (AFG) Program:

“FEMA has been working with the General Services Administration to resolve interface issues related to SAM.gov that were affecting some applicants’ ability to begin inputting their federal fiscal year (FY) 2021 Assistance to Firefighters Grant (AFG) Program applications into the FEMA GO System. Specifically, this issue included applicants that received error messages stating their organizations were not found and that their Unique Entity Identifier (UEI)/Electronic Funds Transfer (EFT) combination did not exist despite the applicants’ SAM.gov accounts being fully active.

As this issue is ongoing, the FY 2021 AFG Program application period will remain open until January 21, 2022 5:00 p.m. ET. All applicants will automatically be granted this extension. This ensures that applicants affected by the UEI/EFT issue will have sufficient time to complete the online application. The extension to the application period will not affect the award timeline. In the meantime, FEMA continues to strongly encourage applicants to review the FY 2021 AFG Program Notice of Funding Opportunity and the associated tools posted on the FEMA website here: FY 2021 Assistance to Firefighters Grant (AFG) Application Guidance Materials | FEMA.gov. In preparation for application submission, applicants may also draft their narratives separately and cut and paste them into the appropriate areas of FEMA GO once the SAM.gov interface issue is resolved. The questions that are asked in the narrative section may be found in the FY 2021 AFG Program Narrative Get Ready Guide.

Fire Grants Help Desk: If you have questions about the NOFO or application process, call or email the Fire Grants Help Desk. The toll-free number is 1-866-274-0960; the e-mail address for questions is firegrants@fema.dhs.gov.The Fire Grants Help Desk is open Monday – Friday, 8 a.m. – 4:30 p.m. ET. “

 

5th Circuit Lifts Injunction on CMS Mandatory Vaccine Requirement for Half of U.S.

On December 15, 2021, the United States Court of Appeals for the Fifth Circuit issued a ruling which modifies an earlier court national injunction related to the CMS mandatory vaccination rules.  In the latest ruling, the court upheld the injunction issued by the United States District Court for the Eastern District of Missouri as it applied to the fourteen (14) plaintiff states, Louisiana, Montana, Arizona, Alabama, Georgia, Idaho, Indiana, Mississippi, Oklahoma, South Carolina, Utah, West Virginia, Kentucky, and Ohio.  However, it overturned the lower court’s expansion of that injunction to other, non-plaintiff states, in the injunction.  Meaning that between the 5th and 8th Circuit Court rulings, the CMS mandatory vaccination injunction only applies to the following 24 states:

5th Circuit Plaintiffs: Louisiana, Montana, Arizona, Alabama, Georgia, Idaho, Indiana, Mississippi, Oklahoma, South Carolina, Utah, West Virginia, Kentucky, Ohio

8th Circuit Plaintiffs: Missouri, Nebraska, Arkansas, Kansas, Iowa, Wyoming, Alaska, South Dakota, North Dakota and New Hampshire.

States not covered by the CMS mandatory vaccination injunction:

California, Colorado, Connecticut, Delaware, Florida, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Tennessee, Texas, Vermont, Virginia, Washington, and Wisconsin

This decision, follows another mandatory vaccine related decision issued by the United States Court of Appeals for the Eleventh Circuit which criticized the Louisiana court for expanding the CMS vaccine mandate nationwide given that a Florida District Court had already refused to issue an injunction and because it felt that it was likely that the mandate was likely authorized under current CMS rules.

What does this mean for employers?

If you are an employer in one of the states not covered by an injunction, you should consult with any covered healthcare facility that your organization performs services under contract. These covered healthcare facilities will be required to mandate vaccination for their staff and for any contractor staff that interacts with their employees or patients.  Additionally, they will be seeking proof that your staff is vaccinated against COVID-19, unless they have a protected medical or religious accommodation.

Employers should have already taken the initial steps toward compliance with the CMS mandatory vaccination rules, including having a list of all employees with their vaccination status.  Additionally, employers should have an established policy related to mandatory vaccination and a procedure for requesting and processing an exception/accommodation requests. Lastly, healthcare institutions may independently institute mandatory vaccination rules for their employees and can require this of anyone entering their facility, including EMS staff.

We will continue to keep you post as these cases proceed through the legal system. These facilities may still independently require your staff to be vaccinated. If your organization has questions or need assistance deciphering or preparing for these requirements, please contact the AAA by emailing hello@ambulance.org.

 

 

 

HRSA Announces Distribution of Phase 4 General Distribution Funds

The Health Resources & Services Administration (HRSA) has announced that it will begin distributing Phase 4 General Distribution Payments on Thursday, December 16, 2021.  According to HRSA, approximately 75% of all Phase 4 applications have now been processed.  HRSA indicated that the remaining 25% of applications require additional review under its risk mitigation and cost containment safeguards.

HRSA further indicated that it began distributing American Rescue Plan (ARP) Rural Payments on November 23, 2021.  As of December 14, 2021, HRSA has indicated that it has processed approximately 96% of ARP applications.  The ARP allocated a total of $8.5 billion to health care providers who serve rural Medicare, Medicaid and CHIP patients.  HRSA indicated that it will distribute $7.5 billion of these funds in its initial distribution.

To the extent a provider was determined to be eligible for either a Phase 4 payment or an ARP Rural Payment, the provider will receive both an email notification and a paper letter with additional details on these payments.  This will include the individual amounts attributed to any subsidiary TINs submitted as part of their application.  To the extent HRSA determined that you were not eligible for a Phase 4 payment, the email notice will provide an explanation for why you were determined to be ineligible.  These email notices will be sent to the email address provided in the Phase 4 application.  Providers selected for additional review will receive email notification as soon as HRSA completes its review process, which it indicated would be completed in “early 2022.”

AAA members are encouraged to look for this email.  If you have not received an email notification, we would suggest that you check your spam filter, as several of our members have indicated that the email was flagged as “spam” by their email system. 

Notice on Ground Ambulance and Patient Billing Advisory Committee

The Centers for Medicare and Medicaid Services (CMS) has filed for publication in the Federal Register the Solicitation of Nominations Notice for the Ground Ambulance and Patient Billing (GAPB) Advisory Committee. The Notice is scheduled to be included in the Federal Register for tomorrow, Tuesday, November 23.

The Congress created the GAPB Advisory Committee as part of The No Surprises Act enacted last year and currently being implemented by the Departments of Health and Human Services, Labor and the Treasury. The American Ambulance Association, International Association of Fire Chiefs, International Association of Fire Fighters, National Association of Emergency Medical Technicians, and the National Volunteer Fire Council successfully advocated that the Congress take into consideration the unique characteristics of ground ambulance services when determining balance billing policy for our services. The Congress excluded ground ambulance services from the provisions of The No Surprises Act and created the GAPB Advisory Committee to address balance billing.

The AAA has identified candidates, including AAA President Baird, who we will be supporting for inclusion on the Advisory Committee who we believe are well-positioned to represent the AAA membership. Once formed, the Advisory Committee has 180 days in which to report its recommendations to the Congress. The directive of the Committee is to review options to “improve the disclosure of charges and fees for ground ambulance services, better inform consumers of insurance options for such services, and protect consumers from balance billing.” We will be keeping the AAA membership continually informed of the actions and deliberations of the GAPB Advisory Committee.

Should you have any questions regarding the GAPB Advisory Committee, please contact AAA Senior Vice President of Government Affairs Tristan North. He can be reached at tnorth@ambulance.org.

It’s Time for EMS to Apply for HHS Provider Relief Fund Tranche 4!

Recorded October 8, 2021 | Free to All | Speaker: Asbel Montes

The deadline for Provider Relief Fund (PRF) applications is 11:59 PM October 26, 2021. If your EMS agency has not yet applied for funds, the American Ambulance Association strongly encourages you to do so! We are happy to answer member questions, just email hello@ambulance.org. Remember, Amber cost data collection software (www.emsamber.com) access is included with your AAA membership and has a PRF module to help you with your application. If you are an AAA member and need help accessing Amber, email shilker@ambulance.org. HRSA is also hosting a technical assistance webinar for PRF applications on October 13, 2021.

Congressional Letter on the EMS Workforce Shortage

October 1, 2021

The Honorable Nancy Pelosi
Speaker of the House
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 & Minority Leader McCarthy,

Our paramedics and emergency medical technicians (EMTs), as well as the organizations that they serve, take on substantial risk every day to treat and transport patients that call 9-1-1. But our nation’s EMS system is facing a crippling workforce shortage, a long-term problem that has been building for more than a decade. It threatens to undermine our emergency 9-1-1 infrastructure and deserves urgent attention by the Congress.

The most sweeping survey of its kind — involving nearly 20,000 employees working at 258 EMS organizations — found that overall turnover among paramedics and EMTs ranges from 20 to 30 percent annually. With percentages that high, ambulance services face 100% turnover over a four- year period. Staffing shortages compromise our ability to respond to healthcare emergencies, especially in rural and underserved parts of the country.

The pandemic exacerbated this shortage and highlighted our need to better understand the drivers of workforce turnover. There are many factors. Our ambulance crews are suffering under the grind of surging demand, burnout, fear of getting sick and stresses on their families. In addition, with COVID-19 halting clinical and in-person trainings for a long period of time, our pipeline for staff is stretched even more.

The challenge is to make sure that the paramedics and EMTs of the future know that EMS is a rewarding destination. Many healthcare providers have extensive professional development resources, but that simply does not exist for EMS. COVID-19 has put additional pressures on the health care system and added another layer of complexity to the emergency response infrastructure.

HRSA EMS Training Funding

Fortunately, there are immediate and long-term solutions. Although the provider relief funds are essential and helpful to address the challenges of the pandemic, we need funding for EMS that addresses paramedic and EMT training, recruitment, and advancement more directly. The Congress can provide specific direction and funds to the Health Resources and Services Administration (HRSA) to help solve this workforce crisis. Those funds can be used to pay for critical training and professional development programs. Some of our members have already begun offering programs and would benefit from additional funding support from HRSA. Funding public-private partnerships between community colleges and private employers to increase the applicant pool and training and employment numbers through grants could overcome the staffing deficit we face.

Paramedic and EMT Direct Pay Bump

In addition, more immediately targeting funds for EMS retention could address the shortage we are experiencing day to day. To help ambulance services retain paramedics and EMTs, we request funds through HRSA to be paid directly to paramedics and EMTs. These earmarked funds could be distributed to each state with specific guidance that the State Offices of EMS distribute the funds to all ground ambulance services using a proportional formula (per field medic).

COVID-19 Medicare Reimbursement Increase

With capitated payments by federal payors, there are limited funds to transfer into workforce initiatives. Increasing Medicare payments temporarily would be meaningful to compete with other employers and other jobs. This could help infuse additional funds into the workforce and create innovative staffing models that take into account hospital bed shortages and overflow.

Congressional Hearings on EMS Workforce Shortage

The workforce shortage crisis facing EMS spans several potential Committees of jurisdiction. This critical shortage is particularly felt in many of our rural and underserved communities. As Congress moves on the steps we have outlined above, we also urge you to organize hearings in the appropriate Committees to develop long-term solutions and focus the country’s attention on these urgent issues.

Thank you in advance for continuing to ensure that our frontline responders have the resources necessary to continue caring for our patients in their greatest moment of need, while maintaining the long-term viability of our nation’s EMS system.

Thank you for your consideration. Sincerely,

Shawn Baird
President
American Ambulance Association

Bruce Evans
President
National Association of Emergency Medical Technicians

Application Open: COVID-19 Provider Relief Funding

From HHS on September 29, 2021

The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced a new application cycle for $25.5 billion in COVID-19 provider funding. Applicants will be able to apply for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments during the application process. PRF Phase 4 is open to a broad range of providers with changes in operating revenues and expenses. ARP Rural is open to providers who serve rural patients covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).
See a detailed list of eligible provider types here.
The application is open now and will close on October 26, 2021 at 11:59 p.m. ET. Providers who have previously created an account in the Provider Relief Fund Application and Attestation Portal and have not logged in for more than 90 days will need to first reset their password before starting a new application. In order to streamline the application process and minimize administrative burdens, providers will apply for both programs in a single application.
HHS recently hosted a briefing session to provide information about these upcoming funding opportunities – view the video here. HRSA will also host webinar sessions featuring guidance on how to navigate the application portal. Register now using the links below.
  • Thursday, September 30 from 3:00 – 4:00 p.m. ET
  • Tuesday, October 5 from 3:00 – 4:00 p.m. ET
  • Two additional webinars the weeks of October 11th and 18th (dates, times, and registration forthcoming)
 
Real time technical assistance is available by calling the Provider Support Line at (866) 569-3522, for TTY dial 711. Hours of operation are 8 a.m. to 10 p.m. CT, Monday through Friday.

HHS PRF Tranche 4 | Important Funding Opportunity for EMS Providers


Speaker: Scott Moore, Esq. | Share on Facebook
This funding opportunity will distribute $25.5 billion in additional Phase 4 General Distribution for EMS agencies and American Rescue Plan (ARP) payments for qualified rural providers who furnish services to Medicaid/CHIP and Medicare beneficiaries. It is critical for all #EMS providers to apply for this funding opportunity regardless of previous funding allocations. We have learned that many EMS providers did not apply for the Tranche 3 funding opportunity because they did not believe that they would be eligible to receive funds under the announced funding formula. Due to the limited number of applicants in Tranche 3, HRSA modified the formula and many who failed to apply would have received funds. We are recommending that all EMS agencies apply to receive the funding that they desperately need. The deadline for applying is 11:59 p.m. on October 26, 2021. There is no penalty for applying.

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.

CMS Releases Medicare COVID-19 Vaccine Data Analysis and PUF

From CMS on August 25, 2021

Today, the Centers for Medicare & Medicaid Services (CMS) released two new resources with information on Medicare beneficiaries on whose behalf at least one fee-for-service (FFS) claim for the administration of the COVID-19 vaccine has been submitted to the Medicare program.

First, we released a paper titled Assessing the Completeness of Medicare Claims Data for Measuring COVID-19 Vaccine Administration. This paper presents preliminary findings on the count of individuals ages 65 and older with at least one COVID-19 vaccine administration claim in the Medicare data compared to the count of people 65+ with at least one COVID-19 vaccine dose in the data reported by the Centers for Disease Control and Prevention (CDC). Using data as of June 4th, 2021, we estimate that CMS received a claim for COVID-19 vaccine administration for roughly half of Medicare beneficiaries who have received at least one COVID-19 vaccine dose as compared to the estimated counts based on adjusted CDC figures (17.5 million out of 36.6 million). As a result, we recommend that the public apply significant caution when analyzing COVID-19 vaccine administration trends using Medicare claims data.

Second, we released the Medicare COVID-19 Vaccine Public Use File (PUF) which presents a high-level and preliminary overview of Medicare utilization and spending information from Medicare FFS claims for the administration of the COVID-19 vaccine. The PUF shows that between December 11, 2020 and June 30, 2021, Medicare payments for administration of the COVID-19 vaccine were over $1.1 billion.  The PUF is based on Medicare FFS claims CMS received by August 6, 2021.

[Note: The Medicare FFS program is paying for COVID-19 vaccine administration on behalf of MA beneficiaries as well as for FFS beneficiaries receiving COVID-19 vaccinations in 2020 and 2021.]

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Provider Relief Fund Reporting Requirement Deadline is Approaching

The American Ambulance Association wants to remind our members that the deadline to submit your initial report on your use of HHS Provider Relief Funds is fast approaching.  Any ambulance provider or supplier that received more than $10,000 in aggregate funds from the first two rounds of General Distribution funding will need to submit a report on their use of such funds by September 30, 2021.  This initial report will detail the expenditure of PRF funds through June 30, 2021.

Relevant Background

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 nation’s coronavirus response.  An additional $75 billion was allocated as part of the Paycheck Protection Program and Health Care Enhancement Act, with subsequent legislation adding further amounts to this fund.  In total, the Provider Relief Fund (PRF) will distribute $178 billion to health care providers and suppliers to fund healthcare-related expenses or to offset lost revenue attributable to COVID-10.

To date, HHS has distributed approximately $148.4 billion through three rounds of General Distribution funds ($92.5 billion) and multiple smaller Targeted Distributions.  A portion of the PRF is also being used to reimburse health care providers for the costs of testing, treating, and vaccinating the uninsured.

Summary of Final Reporting Requirements

On June 11, 2021, HHS issued its final PRF Reporting Requirements.  Under these new guidelines, health care providers will be required to report for any “Payment Received Period” in which they received one or more PRF payments that, in the aggregate, exceed $10,000.  Providers meeting this threshold for any Payment Received Period will report on their use of such funds during the corresponding “Reporting Time Period.”

The following table sets forth the applicable Payment Received Periods and corresponding Reporting Time Periods.  The table also sets forth the deadline to use funds received within each Payment Receiving Period.

 

Period Payment Received Period Deadline for use of Funds Reporting Time Period
1 April 10, 2020 – June 30, 2020 June 30, 2021 July 1, 2021 – September 30, 2021
2 July 1, 2020 – December 31, 2020 December 31, 2021 January 1, 2022 – March 31, 2022
3 January 1, 2021 – June 30, 2021 June 30, 2022 July 1, 2022 – September 30, 2022
4 July 1, 2021 – December 31, 2021 December 31, 2022 January 1, 2023 – March 31, 2023

 

PRF payments received in the first two rounds of General Distribution funding will fall within the first reporting period.  PRF payments received in the third round of General Distribution funding will fall within either the second or third reporting periods, depending on when the funds were actually received.

As a result, ambulance providers and suppliers that received more than $10,000 in the aggregate from the first two rounds of General Distribution funding will need to submit an initial report during the 90-day period starting on July 1, 2021.  This initial report will detail all expenditures of PRF funds through June 30, 2021.

Ambulance providers and suppliers that received between $10,001 and $499,999 in aggregated PRF funds during each Payment Received Period are required to report on their use of such funds in two categories: (1) General and Administrative Expenses and (2) Health Care Related Expenses.  Ambulance providers and suppliers that received $500,000 or more in aggregated PRF funds during each Payment Received Period will be required to submit more detailed information for each of these general categories.

Specific Instructions Related to Reporting of Lost Revenues

The American Ambulance Association has received numerous questions from members regarding the appropriate methodology to report lost revenues attributable to the coronavirus.  Specifically, many members have inquired as to the appropriate methodology for calculating their lost revenues.

HHS has indicated that health care providers must report their lost revenues using one of three methodologies:

  1. The difference between actual patient care revenues;
  2. The difference between budgeted patient care revenues and actual patient care revenues; or
  3. An alternative methodology selected by the provider for estimating lost revenues.

Based on HHS guidance, it appears that the default methodology is to measure the difference between actual patient care revenues for each calendar quarter during the applicable period.  The provider will also be asked to further break down patient care revenues by applicable payer.  In basic terms, the first methodology will compare: (i) your actual calendar year 2019 patient care revenues to (ii) your actual calendar year 2020 patient care revenues.  The A.A.A. suggests that all members start by conducting this basic revenue analysis.  To the extent your lost revenues in 2020 equal or exceed (in combination with your increased expenses, if any) the total PRF funds received during the first Payment Received Period, no additional revenue analysis is required. 

In some instances, you may find that your actual revenue losses for calendar year 2020 do not fully offset the PRF funds received during the First Payment Received Period.  In that event, it may be beneficial to conduct a separate revenue analysis using the budgeted vs. actual methodology.  Note: you are only eligible to use this methodology to the extent you had a formal budget approved prior to March 27, 2020. 

This methodology is likely to be beneficial to ambulance providers or suppliers that, pre-pandemic, were projecting significant revenue growth in calendar year 2020.  For example, consider the case of a hypothetical “ABC Ambulance Service, Inc.”  ABC Ambulance had $1 million in patient care revenues in calendar year 2019.  However, in November 2019, the company signed an agreement to be the preferred provider of a major hospital system in its service area.  As a result, the company was projecting significant revenue growth in calendar year 2020.  Specifically, when it created its 2020 budget in December 2019, it projected that its patient care revenues would rise to $1.5 million in 2020.

When the pandemic hit in mid-March 2020, the company saw a significant slowdown in its transport volume.  Like many ambulance providers, it saw its transport volume rebound somewhat in the 3rd and 4th quarters of 2020.  As a result, it ended the year with $1.2 million in patient care revenues.

A revenue analysis using the default methodology would show an increase in revenues, i.e., its revenues increased by $200,000 over 2019.  However, its 2020 actual revenues were $300,000 less than it projected in its 2020 budget.  Using this second methodology, the company would be able to claim $300,000 in lost revenues to offset against its PRF funds.

Please note that any ambulance provider or supplier using this second methodology will be required to submit additional documentation with its initial PRF report.  Specifically, you will be required to submit a copy of the 2020 budget relied upon to show the lost revenue, together with an attestation from its CEO, CFO, or other authorized official attesting to the fact that this budget was formally established prior to March 27, 2020.

HHS will also permit ambulance providers or suppliers to utilize an alternative methodology created by the entity for calculating their lost revenues.  However, to utilize an alternative methodology, the provider or supplier will be required to submit additional documentation explaining not only the methodology, but also the justification for why this methodology was reasonable.  HHS has indicated that providers or suppliers electing to use an alternative methodology will face an increased risk of audit.  As a good rule of thumb, the use of an alternative methodology is likely to limited to situations where the EMS agency’s business is extremely seasonal, or where there was some major change in their operations during the 2020 calendar year (e.g., a partial sale of the company, a large acquisition, etc.).

Further Information Related to PRF Reporting

HHS updated its instructions for how ambulance providers and suppliers should complete their PRF Reporting obligations.  These updated instructions start on Page 4 of the Revised Reporting Requirements.

HHS also recently updated its Frequently Asked Questions (FAQs) associated with the PRF Reporting Program.

 

 

CMS Addresses Substance Use, Mental Health Crisis Care for Those with Medicaid

CMS Addresses Substance Use, Mental Health Crisis Care for Those with Medicaid

$15 Million Funding Opportunity for State Planning Grants to Bolster Mobile Crisis Intervention Services

The Centers for Medicare & Medicaid Services (CMS) announced a funding opportunity made possible by the American Rescue Plan (ARP) to help states strengthen system capacity to provide community-based mobile crisis intervention services for those with Medicaid. The $15 million funding opportunity is available to state Medicaid agencies for planning grants to support developing these programs.

This funding opportunity provides financial resources for state Medicaid agencies to assess community needs and develop programs to bring crisis intervention services directly to individuals experiencing a mental health or substance use related crisis outside a hospital or facility setting. These services may include screening and assessment, stabilization and de-escalation, and coordination of referrals after the initial treatment.

“Investing in crisis intervention services ensures Americans experiencing a mental health or substance use disorder crisis get the care and treatment they need,” said Secretary Becerra. “These grants will help states build these critical services to help communities send a responder who is trained and ready to assist people in crisis.”

“It is vital that we can meet people where they are, especially when those individuals are in crisis,” said CMS Administrator Chiquita Brooks-LaSure. “This funding will help state Medicaid agencies plan innovative ways to provide and better mobilize these essential intervention services to their communities.”

The planning grants provide funding to develop, prepare for, and implement qualifying community-based mobile crisis intervention services under the Medicaid program. Grant funds can be used to support states’ assessments of their current services, strengthen capacity and information systems, ensure that services can be accessed 24 hours a day/365 days a year, provide behavioral health care training for multi-disciplinary teams, or to seek technical assistance to develop State Plan Amendment (SPAs), demonstration applications, and waiver program requests under the Medicaid program.

Letters of Intent to apply from states and territories are due July 23, 2021. Final applications must be submitted by August 13, 2021, 3:00 pm ET. The period of performance for this grant will be from September 30, 2021, through September 29, 2022. The Notice of Funding Opportunity (NOFO) provides additional details regarding eligibility and program requirements, as well as key deadline and application submission information.

To view the NOFO, visit Grants.gov and search for the announcement by CFDA# 93.639.

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

 

CMS | New Medicaid and CHIP Enrollment Snapshot

FOR IMMEDIATE RELEASE
June 21, 2021

Contact: CMS Media Relations
CMS Media Inquiries

New Medicaid and CHIP Enrollment Snapshot Shows Almost 10 million Americans Enrolled in Coverage During the COVID-19 Public Health Emergency

Report Shows Record Medicaid Enrollment and Highlights the Program’s Importance in Preserving Coverage for Millions of Children and Adults Throughout the United States

The Centers for Medicare & Medicaid Services (CMS) released a new Enrollment Trends Snapshot report today showing a record high, over 80 million individuals have health coverage through Medicaid and the Children’s Health Insurance Program (CHIP).  Nearly 9.9 million individuals, a 13.9% increase, enrolled in coverage between February 2020, the month before the public health emergency (PHE) was declared, and January 2021.

Among the 50 states and the District of Columbia, a total of 80,543,351 people were enrolled and receiving full benefits from the Medicaid and CHIP programs by the end of January 2021. In the 50 states that reported total Medicaid child and CHIP enrollment data for January 2021, over 38.3 million children were enrolled in Medicaid and CHIP combined, approximately 50% of the total Medicaid and CHIP enrollment. These numbers highlight the essential role the Medicaid and CHIP programs play in providing quality and needed coverage for millions of vulnerable children and adults. In fact, both programs serve as the largest single source of health coverage in the country.

“The Biden-Harris administration is using every lever to ensure any American needing access to quality health coverage receives it. Now more than ever, people need the peace of mind of knowing that they have health coverage,” said HHS Secretary Xavier Becerra. “This report reminds us what a critical program and rock Medicaid continues to be in giving tens of millions of children and adults access to care. This pandemic taught us that now more than ever, we must work to strengthen Medicaid and make it available whenever and wherever it’s needed using the unprecedented investments Congress provided.”

The increase in total Medicaid and CHIP enrollment is largely attributed to the impact of the COVID-19 PHE, in particular, enactment of section 6008 of the Families First Coronavirus Response Act (FFCRA). FFCRA provides states with a temporary 6.2% payment increase in Federal Medical Assistance Percentage (FMAP) funding.  States qualify for this enhanced funding by adhering to the Maintenance of Effort requirement, which ensures eligible people enrolled in Medicaid stay enrolled and covered during the PHE.

“Medicaid and CHIP serve as a much-needed lifeline for millions of people throughout this country. The increase we are seeing is exactly how Medicaid works: the program steps in to support people and their families when times are tough,” said CMS Administrator Chiquita Brooks-LaSure. “For the parents that may have lost a job or had another life change during the pandemic, having access to coverage for themselves and their kids is life-changing. CMS is committed to ensuring our nation’s marginalized communities and low-income families have the coverage they need.”

To assist states and territories in their response to the COVID-19 PHE, CMS developed numerous strategies to support Medicaid and CHIP programs in times of crisis, including granting states more flexibility in their Medicaid and CHIP operations. Today’s data release also reflects a range of indicators related to key application, eligibility, and enrollment processes from within state Medicaid and CHIP agencies.

The Snapshot is a product of the Centers for Medicare and Medicaid CHIP Services (CMCS) Medicaid and CHIP Coverage Learning Collaborative (MACLC), which monitors Medicaid and CHIP enrollment trends, primarily using the CMS Performance Indicator (PI) data reported to CMS by state Medicaid and CHIP agencies. PI data reflects key Medicaid and CHIP business processes- including applications, renewals, eligibility determinations, and enrollment.

The Enrollment Trends Snapshot, which is released monthly, is available here:  https://www.medicaid.gov/medicaid/program-information/medicaid-chip-enrollment-data/medicaid-and-chip-enrollment-trend-snapshot/index.html

The complete dataset, including data from January 2021, is available on data.Medicaid.gov.

6/16 | Federal Interagency Committee on EMS Virtual Meeting

Federal Interagency Committee on EMS to Hold Virtual Meeting on June 16

FICEMS also recently approved a new strategic plan to guide Federal activities related to EMS through 2025

The Federal Interagency Committee on EMS, which coordinates EMS activities throughout the federal government, will hold its first virtual meeting of 2021 on June 16 at 1 pm ET. Members of the public are invited to watch the webcast. Visit the FICEMS meeting page to learn more and view the agenda, or click below to register now. Anyone wishing to provide public comment can email FICEMS@dot.gov with “FICEMS Feedback” in the subject line. There will also be opportunities to ask questions or submit comments via a chat function during the webcast.

Register Now

New FICEMS Strategic Plan

One of the items on the agenda for the next FICEMS meeting is the new FICEMS Strategic Plan, which is now available on EMS.gov. The plan will guide FICEMS and its efforts to support and advance EMS and 911 services in the Nation over the next five years. The plan outlines seven strategic goals, each with multiple objectives, that will serve as the foundation for the activities of FICEMS and its member agencies.

Read the FICEMS strategic plan and learn more about the committee’s vision for Federal support of state, local, tribal and territorial EMS.

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