GAPBAC | Registration Open for Oct 31, Nov 1 Meetings
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Prehospital Blood Transfusion Initiative
Press Release from the Prehospital Blood Transfusion Initiative Coalition
PREHOSPITAL BLOOD TRANSFUSION INITIATIVE COALITION BEING FORMED
Contact:
Bill Skillman
bskillman@veli.co
781 315 7537
In cities, towns and rural communities across the US people are dying unnecessarily from severe bleeding arising from limited supply of blood products and lack of blood transfusions after injury or other causes of hemorrhagic shock. Bleeding to death from uncontrolled hemorrhage remains the leading cause of preventable deaths among victims of trauma with nearly half of these patients dying in the prehospital setting. Unfortunately, in the vast majority of cases, blood products are not available on emergency medical response vehicles because of reimbursement limitations and local regulations which vary by state.
The Prehospital Blood Transfusion Initiative Coalition (PHBTIC) is being established to address these problems. “A growing number of ground and air medical EMS programs have successfully initiated blood programs in recent years, but more needs to be done to ensure patients in the U.S. who need prehospital transfusion are able to receive it, regardless of where they live” notes John Holcomb, MD, Professor of Surgery at University of Alabama at Birmingham, an internationally renowned trauma surgeon and expert on civilian and military hemorrhage control and resuscitation. The Coalition, led by a steering committee, is building a multi-disciplinary, collaborative initiative to advance four pillars of focused activity to promote prehospital blood transfusion programs:
- Establish reimbursement for blood products transfused in the prehospital setting.
- EMS scope-of-practice allowing the initiation of prehospital blood products in states where it currently is not allowed.
- Strategic preparedness for homeland defense and mass casualties.
- Outreach and education, including regulatory, protocols, and best practices for programs based on experiences of agencies currently conducting programs.
“Our group represents a diverse community of prehospital and hospital-based medical professionals, as well as industry, blood collection, and government partners, whose focus is on improving outcomes of all patients suffering hemorrhagic shock in a data-driven fashion” say Eric Bank, LP, NRP, Assistant Chief of EMS HCESD 48 Fire-EMS and Randi Schaefer, DNP, RN, Clinical Consultant and Scientific Advisor.
The Steering Committee has already reached out to national stakeholder organizations in the EMS, trauma, blood and industry communities and are soliciting others with an interest in ensuring blood products are available in all emergency settings to join the Coalition. They will be scheduling an initial meeting of the Coalition in the coming weeks. Those interested are encouraged to contact Jon R Krohmer, MD at jrkrohmer@gmail.com
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GAPBAC | AAA Comment Letter on Final Recommendations
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VA Final Rule on Ambulance Services Update
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PBS NewsHour | The No Surprises Act left out ground ambulances. Here’s what’s happening now
Thank you to American Ambulance Association Secretary @WayneJurecki for standing up for patients and #EMS providers. @NewsHour #SupportEMS #GAPBAC #AlwaysOpen #NotJustaRide https://t.co/L982QAYr3X @EMS1 @jemsconnect @UKROBL1 @AIMHI_MIH @EMSWorldOFCL
— AmericanAmbulanceAsc (@amerambassoc) August 24, 2023
GAPBAC | Follow Up from Committee Meeting #2
Ground Ambulance and Patient Billing (GAPB) Advisory Committee Public Meeting #2 (August 16, 2023)
The Ground Ambulance and Patient Billing (GAPB) Advisory Committee Second Public Meeting was held on August 16, 2023. Materials for this meeting are available for download on the CMS.gov GAPB website.
As we continue this webinar series, we look to you as industry experts to provide feedback and recommend information that would be beneficial in future webinars. Written public comments for consideration by the Advisory Committee may be emailed to: GAPBAdvisoryCommittee@
Public comments on the specific topics listed in the GAPB Advisory Committee Public Meeting #2 Agenda, should be submitted by September 5, 2023 for consideration by the GAPB Advisory Committee.
GAPBAC | Second Meeting August 16
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NEMSAC | Meeting August 9-10
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Perez and Finstad Push Medic to Paramedic Provision
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AAA Encourages CMS to Consider Revised Innovation Model for Treatment in Place
Washington, DC— While the Centers for Medicare & Medicaid Services (CMS) has decided to end the Emergency Triage, Treat, and Transport (ET3) Model two years early on December 31, 2023, the American Ambulance Association (AAA) remains committed to working with CMS on all future efforts to design programs that fully utilize the ground ambulance services in the delivery of mobile healthcare services. CMS made the decision to end the model “due to lower than expected participation and lower than projected interventions.”
The AAA is encouraged that CMS has stated that, “the lessons learned from the ET3 Model can aid in the development of potential future initiatives.” Our members are committed to supporting such future efforts to make sure that the requirements support true treatment in place and recognize the unique needs of rural ground ambulance services and the communities they serve. Moreover, we encourage CMS to work with the AAA to move forward with alternative destination as a permanent policy based not only on the lessons learned from the ET3 model, but also those garnered as a result of the Public Health Emergency (PHE) waiver. The AAA continues to support efforts to refine the Medicare ground ambulance emergency benefit to support delivering pre-hospital services to the patients who need them at the time they need them and where they need them.
CMS Releases Advance Copy of CY 2024 Physician Fee Schedule Proposed Rule
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7/27 CMS Ambulance Open Door Forum
From CMS on July 19, 2023
The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, July 27, 2023
Start Time: 2:00pm-3:00pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
- Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
Announcements & Updates
- Ground Ambulance & Patient Billing Advisory Committee Meeting Announcement
- Update on Emergency Triage, Treat, and Transport (ET3) Model
- Medicare Ground Ambulance Data Collection System (GADCS): Proposed Changes in the CY 2024 Physician Fee Schedule Proposed Rule
- Slide presentation will be available at: https://www.cms.gov/
medicare/ambulance-fee- schedule-zip-code-files/ ambulance-events
- Slide presentation will be available at: https://www.cms.gov/
- Consolidated Appropriations Act, 2023: Division FF, section 4103: Extension of Add-On Payments for Ambulance Services
III. Open Q&A
**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
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This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.
NEW and UPDATED Open Door Forum Participation Instructions:
This call will be a Zoom webinar with registration and login instructions below.
Register in advance for this webinar:
https://cms.zoomgov.com/
Webinar ID: 161 099 7532
Passcode: 131371
After registering, you will receive a confirmation email containing information about joining the webinar. You may also add the webinar to your calendar using the drop-down arrow on the “Webinar Registration Approved” webpage after registering. Although the ODFs are now a Zoom webinar, we will only use the audio function, no need for cameras to be on.
For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/
Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. The webinar recording and transcript will be posted to: https://www.cms.gov/Outreach-
CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.
SCOTUS Decision Changes Religious Accommodation Standard
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EEOC Weighs in on SCOTUS Decision On Affirmative Action Programs in Education
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A Message from AAA President Randy Strozyk
Contact Congress ►https://www.votervoice.net/Ambulance/…
Annual Conference & Trade Show June 26–28, 2023 in Las Vegas ► https://annual.ambulance.org/
NCSL EMS Legislative Database
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Preserving Access to Ground Ambulance Medical Services Act of 2023
Earlier today, Senators Catherine Cortez Masto (D-NV), Susan Collins (R-ME), Debbie Stabenow (D-MI) and Bill Cassidy, MD (R-LA) introduced the Preserving Access to Ground Ambulance Medical Services Act of 2023. The legislation would extend the temporary Medicare ambulance add-on payments for an additional three years.
“We thank Senators Cortez Masto, Collins, Stabenow, and Cassidy for introducing the Preserving Access to Ground Ambulance Medical Services Act and for their strong support for ground ambulance services and the communities and patients we serve,” said AAA President Randy Strozyk. “The disparity between Medicare reimbursement and the costs of providing services has grown significantly through reductions in reimbursement and skyrocketing expenses for labor, ambulances, and equipment. This bill would help reduce that gap and maintain access to vital ground ambulance services for communities around the country.”
The Senate version of the bill would go even further by increasing the add-on payment levels for urban from 2% to 3.4% urban, for rural from 3% to 4.3% rural and for super rural from 22.6% 26.2%. The last extension of the add-on payments was scheduled to end on December 31, 2022, but our champions on Capitol Hill were able to secure a two-year extension through December 31, 2024. The additional three-year extension is critical to keep the add-on payments in place through ambulance data collection and provide time to Congress to then use the data to reform the Medicare ambulance fee schedule.
Representatives Brad Wenstrup (R-OH), Terri Sewell (D-AL), Buddy Carter (R-GA) and Paul Tonko (D-NY) introduced the House version (H.R. 1666) of the bill on March 17. The House bill would be a three-year extension of the add-on payments at their present levels.
This progress is the result of tireless advocacy on the part of AAA volunteer leaders, staff, and consultants made possible by the sustained support of our members. It is critical that AAA members reach out to both their Senators and Representatives to cosponsor the respective versions of the Preserving Access to Ground Ambulance Services Act of 2023. It is vital that we generate a groundswell of support in the Congress for extending the add-on payments and will need that support to then also advocate for the higher add-on percentages when Congress negotiates on Medicare payment extensions.
CMS | Updates to Coverage for COVID-19 Tests
The COVID-19 Public Health Emergency is to end on May 11, 2023. The ending of the Public Health Emergency may impact an individual’s coverage of COVID-19 tests. We encourage you to know these changes and share the New Consumer Fact Sheet on COVID-19 tests.
Consumer Fact Sheets:
- English – https://www.cms.gov/files/
document/covid-over-counter- test-coverage.pdf - Spanish – https://www.cms.gov/files/
document/covid-over-counter- test-coverage-spanish.pdf
Before May 11, 2023
If you have any type of health insurance, you can get up to eight over-the-counter tests per month with no out-of-pocket costs. Over-the-counter tests are available in most pharmacies and may also be available online for delivery.
After May 11, 2023
Laboratory tests for COVID-19 that are ordered by your provider will still be covered with no out-of-pocket costs for people with Medicare. Over-the-counter tests will still be available, but there may be out-of-pocket costs. Coverage of over-the-counter tests may vary by your insurance type, as described below.
What does this mean for Medicare Beneficiaries?
Generally, Medicare doesn’t cover or pay for over-the counter products. The demonstration that has allowed us to offer coverage for COVID-19 over-the-counter tests at no cost ends on May 11, 2023.
However, if you are enrolled in Medicare Part B, you will continue to have coverage with no out-of-pocket costs for appropriate laboratory-based COVID-19 PCR and antigen tests, when a provider orders them (such as drive-through PCR and antigen testing or testing in a provider’s office).
If you are enrolled in a Medicare Advantage plan, you may have more access to tests depending on your benefits. Check with your plan.
What does this mean for people with Medicaid or Children’s Health Insurance Program?
If you have coverage through Medicaid or the Children’s Health Insurance Program, you will have access to COVID-19 over-the-counter and laboratory testing through September 30, 2024. After that date, coverage of testing may vary by state.
What does this mean for people with Private Insurance?
If you have private insurance, coverage will vary depending on your health plan. However, private plans won’t be required by federal law to cover over-the counter and laboratory-based COVID-19 tests after
May 11, 2023. If your insurance chooses to cover COVID-19 testing, they may require cost sharing, prior authorization, or other forms of medical management.
OIG Announces Modernization of Compliance Program Guidance Documents
By Brian S. Werfel, Esq.
On April 25, 2023, the HHS Office of the Inspector General (OIG) posted a notice in the Federal Register that it would be updating its publicly available resources, including its compliance program guidance documents. The OIG’s Compliance Program Guidances (CPGs) were developed as voluntary, non-binding guidance documents that can assist healthcare providers in developing their own internal controls to ensure adherence to federal laws, regulations, and program requirements.
Specifically, the OIG announced that it will no longer publish updated or new CPGs in the Federal Register. Instead, updates or new CPGs will now be made available on the OIG’s website. The OIG will also revise the format for CGS. The new format will consist of: (1) a General CPG (GCPG) that applies to all healthcare providers and (2) industry-specific CPGs (ICPGs) tailored to the fraud and abuse areas specific to that industry. The OIG indicated that it anticipates issuing the GCPG by the end of calendar year 2023, with ICPGs being issued starting in calendar year 2024. The OIG further indicated that it anticipates the first two ICPGs will address Medicare Advantage plans and nursing facilities.
Note: the OIG is not updating its 2003 guidance on compliance programs for ambulance suppliers. The OIG frequently cites this document in enforcement actions it takes against ambulance providers and suppliers. Thus, this guidance document remains relevant to this day. For that reason, A.A.A. members are strongly encouraged to review this document to ensure that their existing compliance program incorporates the elements cited by the OIG.
Previous Compliance Program Guidance for Ambulance Suppliers
In March 2003, the OIG issued its “Compliance Program Guidance for Ambulance Suppliers.” This document sets forth the basic elements that it believes should be included in any effective compliance program, and then discusses various fraud and abuse and compliance risks associated with the provision of ambulance services under the Medicare Program.
The 7 basic elements identified by the OIG are:
- The development of compliance policies and procedures
- The designation of a compliance officer or compliance committee
- The implementation of education and training programs
- The use of internal monitoring and reviews
- Policies designed to respond appropriately to detected misconduct
- Ensuring open lines of communication
- The enforcement of disciplinary standards through well-publicized guidelines
The CPG then goes into greater detail on each of these elements, including specific recommendations on how to properly implement each of these elements. For instance, the OIG suggests that the organization’s compliance office be a high-level individual who reports directly to the organization’s CEO or Board of Directors.
With respect to the specific fraud and abuse risks associated with ambulance, the OIG highlighted the issue of medical necessity. The OIG also cited level of service issues (i.e., billing ALS vs. BLS), non-emergency transports, and coordination of benefit issues as particular areas of concern.
GAPBAC | First Meeting May 2 & 3
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