Ground Ambulance and Patient Billing Advisory Committee Update
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orThis week, Senator Sheldon Whitehouse (D-RI) along with Senator Alex Padilla (D-CA), introduced the Student Loan Forgiveness for Frontline Health Workers Act (S. 3828), which provides loan forgiveness to individuals working in frontline healthcare responding to the Covid-19 pandemic. The legislation broadly defines healthcare workers and includes those who work in both public and private EMS. It provides relief to those who participate in both Federal student loans and private loans. We are very pleased to see the introduction of this legislation as it represents the kind of broad-based coverage for both governmental and non-governmental EMS that we have been advocating for. The legislation specifically covers paramedic certification programs that are accredited as part of CoAEMSP which requires college affiliation and makes them eligible for relief as federal student loans. The bill has broader standards than the current Public Safety Loan Forgiveness program. S. 3828 covers front-line healthcare workers regardless of their length of service as long as they are providing Covid healthcare-related services and specifically covers “an emergency medical services worker who responds to health emergencies or transports patients to hospitals or other medical facilities”. In addition, the student loan forgiveness for those working in EMS, would be exempt from inclusion in that individual’s taxable income.
The AAA supports this legislation and applauds Senator Whitehouse and Senator Padilla for their efforts to assist our frontline healthcare workers.
Last night, the United States Senate passed language as part of the FY 2022 Omnibus Appropriations Package that would delay the due date of the Medicare Payment Advisory Committee (MedPAC) report analyzing ambulance cost data. The U.S. House of Representatives had passed the package on Wednesday. The delay in the MedPAC report is a victory for the AAA and our members as we spearheaded efforts for the delay.
We thank Senators Chuck Schumer, Catherine Cortez Masto, Ron Wyden, Mike Crapo and Debbie Stabenow and Representatives Richard Neal, Kevin Brady, Frank Pallone and Catherine McMorris Rogers for championing and assisting with passage of the provision.
The delay in the timing of the MedPAC report was necessary due to CMS postponing the beginning of ambulance cost data collection by two years to account for the COVID-19 pandemic. Even though data collection had been delayed, MedPAC indicated that they were compelled to stick to the statutory deadline of issuing a report – with very little or no new ambulance data – to Congress by March 15, 2023.
With little to no new data, MedPAC would have likely reinstated their recommendations from their 2002 ambulance report which did support most of the temporary ambulance increases but at the cost of cutting BLS non-emergency services by 5.75%. MedPAC had also recommended doing away with rural and super rural increases in favor of a low volume adjuster which would disrupt reimbursement levels for rural providers without having more detailed data if indeed the proper approach.
The language from the FY2022 Omnibus Appropriations Package is as follows:
SEC. 311. REVISION OF THE TIMING OF MEDPAC REPORT ON AMBULANCE COST DATA.
Section 1834(l)(17)(F)(i) of the Social Security Act (42 U.S.C. 1395m(l)(17)(F)(i)) is amended by striking ‘‘Not later than March 15, 2023, and as determined necessary by the Medicare Payment Advisory Commission thereafter’’ and inserting ‘‘Not later than the second June 15th following the date on which the Secretary transmits data for the first representative sample of providers and suppliers of ground ambulance services to the Medicare Payment Advisory Commission, and as determined necessary by such Commission thereafter,’’.
Next week, we will be launching a Call to Action asking AAA members to reach out to their members of Congress to cosponsor the Protecting Access to Ground Ambulance Medical Services Act (H.R. 2454, S. 2037) Medicare Ambulance which would extend the temporary Medicare ambulance increases for five years. The increases expire at the end of this year and the five-year extension is necessary to provide time for the MedPAC report and the Congress to act.
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orFrom FAIR Health in February 2022
“Currently, no federal law protects consumers against “surprise” bills from out-of-network ground ambulance providers. Some state and local governments regulate ground ambulance surprise billing practices; however, such laws may not apply to all health plans or ambulance providers in an area. Because of the substantial policy interest in ground ambulance services, FAIR Health drew on its vast database of private healthcare claims to illuminate multiple aspects of such services across the nation, including utilization, costs, age, gender, diagnoses and differences across states.”
Fantastic Bloomberg Radio interview with President Shawn Baird covering key causes and impacts of the EMS workforce shortage.
Balance of Power Podcast • Browse all episodes
https://www.bloomberg.com/news/audio/2022-02-11/balance-of-power-ems-worker…
Balance of Power: EMS Worker Shortage Crisis (Radio)
Shawn Baird, President of the American Ambulance Association, discusses the shortage of emergency medical workers and paramedics. He spoke with Bloomberg’s David Westin.
Committee on Ways and Means
U.S. House of Representatives Hearing on “America’s Mental Health Crisis”
Statement of Shawn Baird, President, American Ambulance Association
February 2, 2022
Chairman Neal, Ranking Member Brady, and members of the Committee, on behalf of the members of the American Ambulance Association (AAA), I greatly appreciate the opportunity to provide you with a written statement on America’s Mental Health Crisis. Simply put, America’s hometown heroes who provide emergency medical services and transitional care need the Congress to recognize the significant stress and trauma paramedics and emergency medical technicians (EMTs) have experienced as a result of this pandemic. The AAA urges members of Congress not to forget these heroes and to expressly include all ground ambulance service personnel in efforts to address America’s Mental Health Crisis.
Emergency medical services (EMS) professionals are ready at a moment’s notice to provide life-saving and life-sustaining treatment and medical transportation for conditions ranging from heart attack, stroke, and trauma to childbirth and overdose. These first responders proudly serve their communities with on-demand mobile healthcare around the clock. Ground ambulance service professionals have been at the forefront of our country’s response to the mental health crisis in their local communities. Often, emergency calls related to mental health services are triaged to the local ground ambulance service to address.
While paramedics and EMTs provide important emergency health care services to those individuals suffering from a mental or behavioral health crisis, these front-line workers have been struggling to access the federal assistance they need to address the mental health strain that providing 24-hour care, especially during a COVID-19 pandemic, has placed on them. We need to ensure that there is equal access to mental health funding for all EMS agencies, regardless of their form of corporate ownership so that all first responders can receive the help and support they need.
EMS’s Enhanced Role in the Pandemic
As if traditional ambulance service responsibilities were not enough, paramedics and EMTs have taken on an even greater role on the very front lines of the COVID-19 pandemic. In many areas, EMS professionals lead Coronavirus vaccination, testing, and patient navigation. As part of the federal disaster response subcontract, EMS personnel even deploy to other areas around the country to pandemic hotspots and natural disasters to bolster local healthcare resources in the face of extraordinarily challenging circumstances.
Mental & Behavioral Health Challenges Drive Staffing Shortages on the Front Line
Myriad studies show that first responders face much higher-than-average rates of post- traumatic stress disorder[1], burnout[2], and suicidal ideation[3]. These selfless professionals work in the field every day at great risk to their personal health and safety—and under extreme stress.
Ambulance service agencies and fire departments do not keep bankers’ hours. By their very nature, EMS operations do not close during pandemic lockdowns or during extreme weather emergencies. “Working from home” is not an option for paramedics and EMTs who serve at the intersection of public health and public safety. Many communities face a greater than 25% annual turnover[4] of EMS staff because of these factors. In fact, across the nation EMS agencies face a 20% staffing shortage compounded by near 20% of employees on sick leave from COVID-19. This crisis-level staffing is unsustainable and threatens the public safety net of our cities and towns.
Sadly, to date, too few resources have been allocated to support the mental and behavioral health of our hometown heroes. I write today to ask for Congressional assistance to help the helpers as they face the challenges of 2022 and beyond.
Equity for All Provider Types
Due to the inherently local nature of EMS, each American community chooses the ambulance service provider model that represents the best fit for its specific population, geography, and budget. From for-profit entities to municipally-funded fire departments to volunteer rescue squads, EMS professionals share the same duties and responsibilities regardless of their organizational tax structure. They face the same mental health challenges and should have equal access to available behavioral health programs and services.
Many current federal first responder grant programs and resources exclude the tens of thousands of paramedics and EMTs employed by for-profit entities from access. These individuals respond to the same 911 calls and provide the same interfacility mobile healthcare as their governmental brethren without receiving the same behavioral health support from
Federal agencies. To remedy this and ensure equitable mental healthcare access for all first responders, we recommend that:
The rationale for the above requests is twofold. First, ensuring the mental health and wellness of all EMS professionals—regardless of their employer’s tax status—is the right thing to do.
Second, because keeping paramedics and EMTs employed by private ambulance agencies who are on the frontlines of providing vital medical care and vaccinations during this pandemic is the smart thing to do.
Thank you for considering this request to support ALL of our nation’s frontline heroes. They are ready to answer your call for help, 24/7—two years into this devastating pandemic, will Congress answer theirs?
Please do not hesitate to contact American Ambulance Association Senior Vice President of Government Affairs, Tristan North, at tnorth@ambulance.org or 202-486-4888 should you have any questions.
Yesterday, the American Ambulance Association Board of Directors approved the Association’s advocacy priorities for 2022. Our key initiatives reflect the challenges we face this year, including short-sighted threats to EMS balance billing, a worsening workforce shortage, the expiration of the temporary Medicare increases, and potential sequestration cuts.
We also continue to fight for you as you care for people first on the frontlines of the COVID-19 pandemic. We will sustain our efforts at securing additional funding for ground ambulance services to help address the increased costs of providing medical care and transport during the Public Health Emergency.
To achieve our collective goals, the AAA Board will need to mobilize the full voice of influence of the EMS community this year. If you have not already sent an email using the AAA advocacy system to your members of Congress, please do so today!
Staff will be reaching out to you at key points later in the year about letter writing for specific individual policy requests. But it is important that they hear from you now on all the top issues for ground ambulance services. They are:
With the persistent shortage of ground ambulance service field personnel raising to a crisis level with the COVID-19 pandemic, the AAA moved the issue to a top policy priority. The AAA is currently working with key Congressional Committees of jurisdiction to hold hearings on the EMS workforce shortage. We are also developing legislation to specifically target increasing access for ground ambulance service organizations to federal programs and funding for the retention and training of health care personnel.
The AAA successfully educated the Congress on the role of local government oversight and other unique characteristics of providing ground ambulance service organizations. As a result, the Congress directed the establishment of a Ground Ambulance and Balance Billing Advisory Committee to address the issue. The Committee is in the process of being formed and then has 180 days in which to make recommendations to the Congress. The AAA will be involved with the Committee and advocating that the Congress implement policies that meet the needs of our members.
The AAA is advocating for additional financial assistance for ground ambulance service organizations to help address the increased costs of labor and other higher costs associated with providing health care during the COVID-19 pandemic.
The temporary Medicare ambulance increases of 2% urban, 3% rural and the super rural bonus payment expire at the end of the year. The AAA will continue to push for passage of the provisions of the Preserving Access to Ground Ambulance Medical Services Act (S. 2037, H.R. 2454) before the provisions expire as well as for the adoption of language to ensure truly rural areas remain rural following changes to geographical designations based on the 2020 census.
The Congress delayed the additional 4% sequestration cut for only one yea. The AAA is working with other EMS and health care provider and supplier groups to permanently prevent the cut from going into effect as well as further extending the moratorium on the long-standing 2% cut.
With the 2-year delay of ambulance data collection due to the pandemic, the Medicare Payment Advisory Committee (MedPAC) will have little to no data to analyze in March 2023 in which to make recommendations to the Congress on Medicare ambulance payment policy and rates. The AAA is asking the Congress to push back the date of the MedPAC report and also expand the modified data collection timeline of two years to the intended four years.
On behalf of my fellow board members, I again thank you for your continued membership and participation. We look forward to serving you for many years to come.
Should you have any questions regarding our advocacy priorities, please contact AAA Senior Vice President of Government Affairs Tristan North at tnorth@ambulance.org.
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orCenters for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight
Special Open Door Forum: Provider Requirements under the No Surprises Act
Wednesday December 8, 2021 | 2:00-3:00 pm Eastern Time
Conference Call Only
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468
The Center for Consumer Information and Insurance Oversight (CCIIO) and the CMS Office of Communication will host an orientation to provider requirements under the No Surprises Act.
Starting January 1, 2022, consumers will have new billing protections when getting emergency care, non-emergency care from out-of-network providers at in-network
On July 1, 2021, the “Requirements Related to Surprise Billing; Part I,” interim final rule was issued to restrict surprise billing for patients in job-based and individual health plans who get emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers.
On September 30, 2021, a second interim final rule was issued and is open for public comment. The “Requirements Related to Surprise Billing; Part II” rule provides additional protections against surprise medical bills, including:
Together, these lay the groundwork to provide consumers with protection against surprise billing, starting in 2022. Learn more about how these rules help consumers.
Here is the link to our No Surprises page that has the slides: https://www.cms.gov/
We look forward to your participation.
Special Open Door Participation Instructions:
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468
Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.
A transcript and audio recording of this Special ODF will be posted to the Podcast and Transcripts website at https://www.cms.gov/
For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at http://www.cms.gov/
Thank you for your interest in CMS Open Door Forums.
From CMS on December 3, 2021
Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight
Special Open Door Forum: Provider Requirements under the No Surprises Act
Wednesday December 8, 2021 | 2:00-3:00 pm Eastern Time
Conference Call Only
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468
The Center for Consumer Information and Insurance Oversight (CCIIO) and the CMS Office of Communication will host an orientation to provider requirements under the No Surprises Act.
Starting January 1, 2022, consumers will have new billing protections when getting emergency care, non-emergency care from out-of-network providers at in-network
On July 1, 2021, the “Requirements Related to Surprise Billing; Part I,” interim final rule was issued to restrict surprise billing for patients in job-based and individual health plans who get emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers.
On September 30, 2021, a second interim final rule was issued and is open for public comment. The “Requirements Related to Surprise Billing; Part II” rule provides additional protections against surprise medical bills, including:
Together, these lay the groundwork to provide consumers with protection against surprise billing, starting in 2022. Learn more about how these rules help consumers.
Here is the link to our No Surprises page that has the slides: https://www.cms.gov/
We look forward to your participation.
Special Open Door Participation Instructions:
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468
Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.
A transcript and audio recording of this Special ODF will be posted to the Podcast and Transcripts website at https://www.cms.gov/
For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at http://www.cms.gov/
Thank you for your interest in CMS Open Door Forums.
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orPlease either Join!
orOur nation’s EMS infrastructure is at risk. Ground ambulance service organizations are facing a financial crisis due to the lack of adequate reimbursement for their services and a crippling shortage of paramedics and EMTs. If Congress does not act soon, the situation will become worse with an additional 4% sequestration cut for all Medicare providers and suppliers including for ground ambulance services. Our nation’s 9-1-1 EMS infrastructure is at risk.
Place follow the link below to contact your members of Congress and ask that they protect ground emergency and non-emergency ambulance services in our communities.
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.
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.
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.
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).
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.
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
Please either Join!
orFrom HHS on September 29, 2021