The American Ambulance Association has submitted comments to the Senate Committee on Health, Education, Labor, and Pensions (HELP) in response to their request for input on crafting legislation to address the health care workforce shortage.
Ground ambulance service organizations are facing a severe shortage of paramedics and EMTs which is placing a significant strain on an emergency medical system already in financial distress. We greatly appreciate the opportunity to provide our legislative solutions to the committee to help address the ongoing workforce crisis.
Please see the document linked below, which was sent to the HELP Committee Chairman, Senator Bernie Sanders, and the Ranking Member, Senator Bill Cassidy.
Notice Of Funding Opportunity for 2023 Rural EMS Training Grant Program
Applications due May 1, 2023
The Substance Abuse and Mental Health Services Administration (SAMHSA), part of the U.S. Department of Health and Human Services, has announced a Notice Of Funding Opportunity (NOFO) for the 2023 Rural EMS Training Grant Program. There have been important revisions to the amount of funding available and the anticipated number of awards that will be granted.
SAMHSA encourages rural EMS agencies (both fire-based and non-fire based) operated by a local or tribal government, as well as rural non-profit EMS agencies, to apply.
Review the NOFO announcement for a full description of the training program, eligibility information and award details. All applications are due May 1, 2023.
The goal of this SAMHSA program is to recruit and train EMS personnel in rural areas with a particular focus on addressing substance use disorders (SUD) and co-occurring disorders (COD) substance use and mental disorders. Grant recipients will be expected to train EMS personnel on SUD and COD, trauma-informed, recovery-based care for people with such disorders in emergency situations and, as appropriate, to maintain licenses and certifications relevant to serve in an EMS agency.
The next CMS Ambulance Open Door Forum scheduled for:
Thursday, March 16, 2023
2:00pm-3:00pm PM Eastern Time (ET);
This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
II. Announcements & Updates
• Medicare Ground Ambulance Data Collection System
(GADCS): Top 5 Tips for Selected Organizations in Year 1, 2, 3, and 4
Slide presentation will be available on CMS’ Ambulances
Services Center website: https://www.cms.gov/medicare/ambulance-fee-schedule-zipcode-files/ambulance-events
Please see the following information regarding COVID-19
PHE Updated Guidance for Ambulance Organizations:
Public Health Emergency (PHE) 1135 Waivers: Updated
Guidance for Providers
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.
Open Door Participation Instructions:
This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849
Persons participating by phone do not need to RSVP. 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.
Instant Replay: 1-800-814-6745; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
800-814-6745 and entering the Conference Passcode beginning 1 hours after the call
has ended. The recording is available until March 18, 2023, 11:59PM ET.
For ODF schedule updates and E-Mailing List registration, visit our website at
http://www.cms.gov/OpenDoorForums/.
Were you unable to attend the recent Ambulance ODF call? We encourage you to
visit our CMS Podcasts and Transcript webpage where you can listen and view the
most recent Ambulance ODF call. The audio and transcript will be posted to:
https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.
CMS provides free auxiliary aids and services including information in accessible
formats. Click here for more information. This will point partners to our CMS.gov
version of the “Accessibility & Nondiscrimination notice” page. Thank you.
On February 16, 2023, the Department of Veterans published in the Federal Register the final rule to revise the payment methodology for beneficiary travel by ambulance and other so-called “special modes of transportation. The changes contained within the final rule were first included in a November 5, 2020 proposed rule.
The final rule will become effective on February 16, 2024.
Relevant Background
The VA currently pays for beneficiary travel under certain circumstances. To be eligible for reimbursement, the veteran must meet certain eligibility criteria. Specifically, the veteran must be traveling either: (i) for care at a VA health facility or (ii) for care at a non-VA facility that has been previously approved by the VA. The veteran must also meet one of the following additional criteria:
The veteran must have a VA disability rating of 30% or higher;
The veteran must be traveling for treatment of a service-related condition (if their VA disability rating is less than 30%);
The veteran receives a VA pension;
The veteran has an income below the maximum annual VA pension rate;
The veteran cannot otherwise afford to pay for their travel; or
The veteran is traveling for one of the following reasons: (i) to obtain a VA compensation and pension exam, (ii) to obtain a VA service dog, or (iii) to obtain VA-approved transplant care.
Beneficiary travel covers all modes of transportation, including transportation by private vehicle, common carriers (e.g., taxi, livery, and public transportation), mass transit, etc. Beneficiary travel also covers so-called “special modes of transportation,” which includes air and ground ambulance services, wheelchair vans services, and stretcher vans services.
The rules governing the payment for beneficiary travel services at set forth in 38 C.F.R. § 70.30.
Subpart (a)(4) sets forth the payment methodology for the reimbursement of special modes of transport, and simply provides that payment is based on “[t]he actual cost of a special mode of transportation. In the context of ambulance services, this has historically been interpreted to mean the ambulance provider’s full billed charges.
Provisions of Final Rule
Under the final rule, the VA would revise its existing payment methodology for beneficiary travel by ambulance and other special modes of transportation to no longer reimburse providers for their actual costs, and to instead base reimbursement on:
For ground and air ambulance services, the lesser of: (i) the actual charge for ambulance transportation (i.e., the provider’s billed charges) or (ii) the amount determined under the Medicare Ambulance Fee Schedule.
For other special modes of transportation (i.e., ambulette, wheelchair van, or stretcher van), the lesserof: (i) the provider’s actual charge, (ii) the applicable Medicaid rate in the state where the provider is domiciled (using the lowest Medicaid rate where the provider is domiciled in multiple states), or (iii) the applicable Medicaid rate in the state where the transport occurred (or the lowest Medicaid rate if the transport occurred in more than one state). Note: the revised regulations provide that if none of the states involved has a “posted rate,” the VA would continue to pay the provider’s full billed charges
The revised payment methodology for non-ambulance special modes of transport is intended to be temporary. In its proposed rule, the VA indicated that it would use this payment methodology for a minimum of 90 calendar days after a final rule was posted in the Federal Register. This period of time was intended to allow the VA to gather payment data. If the VA believes that it gathered sufficient payment data during this initial 90-day period, it indicated that it would develop a new payment methodology “using the lowest possible rate.” If the VA determined that it did not have sufficient payment data after the initial 90-day period, it would extend the proposed payment methodology for additional 90-day periods as needed until it believed it had sufficient data. The VA indicated that it did not anticipate needing more than 18 months from the effective date of the final rule to gather sufficient payment data to implement a new payment method
These models join the 10 models that released data in 2022, bringing the total to 12 models represented in the CMMI Model Data Sharing (CMDS) model participation files. Each model in the release will include a set of three files, one per participant type (entity, provider, beneficiary). Each set of files will be updated on a quarterly basis, reflecting changes captured for the prior quarter. Quarterly updates will include “full replacement files” and will contain data from the launch of each model to the current quarter. The group of models for which files are available will expand over time to include additional models.
Additionally, CMS is announcing the availability of new Research Identifiable Files (RIFs) for the 2018-2020 performance years for the Comprehensive ESRD Care (CEC) Model. Two RIFs are available for each model year:
The CEC Beneficiary RIF contains enrollment data for beneficiaries in the CEC Model for a given model year
The CEC Provider RIF contains identifying information about the providers participating in the CEC Model for that year.
CMS will also be releasing the Public Use Files (PUFs) for performance years 4 and 5 on the CEC website. These files contain public information about the model participants and their performance. For more information on the model visit https://innovation.cms.gov/innovation-models/comprehensive-esrd-care.
STATEMENT OF ADMINISTRATION POLICY H.R. 382 – A bill to terminate the public health emergency declared with respect to COVID-19
(Rep. Guthrie, R-KY, and 19 cosponsors)
H.J. Res. 7 – A joint resolution relating to a national emergency declared by the President on March 13, 2020
(Rep. Gosar, R-AZ, and 51 cosponsors)
The COVID-19 national emergency and public health emergency (PHE) were declared by the Trump Administration in 2020. They are currently set to expire on March 1 and April 11, respectively. At present, the Administration’s plan is to extend the emergency declarations to May 11, and then end both emergencies on that date. This wind-down would align with the Administration’s previous commitments to give at least 60 days’ notice prior to termination of the PHE.
To be clear, continuation of these emergency declarations until May 11 does not impose any restriction at all on individual conduct with regard to COVID-19. They do not impose mask mandates or vaccine mandates. They do not restrict school or business operations. They do not require the use of any medicines or tests in response to cases of COVID-19.
However, ending these emergency declarations in the manner contemplated by H.R. 382 and H.J. Res. 7 would have two highly significant impacts on our nation’s health system and government operations.
First, an abrupt end to the emergency declarations would create wide-ranging chaos and uncertainty throughout the health care system — for states, for hospitals and doctors’ offices, and, most importantly, for tens of millions of Americans. During the PHE, the Medicaid program has operated under special rules to provide extra funding to states to ensure that tens of millions of vulnerable Americans kept their Medicaid coverage during a global pandemic. In December, Congress enacted an orderly wind-down of these rules to ensure that patients did not lose access to care unpredictably and that state budgets don’t face a radical cliff. If the PHE were suddenly terminated, it would sow confusion and chaos into this critical wind-down. Due to this uncertainty, tens of millions of Americans could be at risk of abruptly losing their health insurance, and states could be at risk of losing billions of dollars in funding. Additionally, hospitals and nursing homes that have relied on flexibilities enabled by the emergency declarations will be plunged into chaos without adequate time to retrain staff and establish new billing processes, likely leading to disruptions in care and payment delays, and many facilities around the country will experience revenue losses. Finally, millions of patients, including many of our nation’s veterans, who rely on telehealth would suddenly be unable to access critical clinical services and medications. The most acutely impacted would be individuals with behavioral health needs and rural patients.
Second, the end of the public health emergency will end the Title 42 policy at the border. While the Administration has attempted to terminate the Title 42 policy and continues to support an orderly lifting of those restrictions, Title 42 remains in place because of orders issued by the Supreme Court and a district court in Louisiana. Enactment of H.R. 382 would lift Title 42 immediately, and result in a substantial additional inflow of migrants at the Southwest border. The number of migrants crossing the border has been cut in half, approximately, since the Administration put in place a plan in early January to deter irregular migration from Venezuela, Cuba, Nicaragua, and Haiti. The Administration supports an orderly, predictable wind-down of Title 42, with sufficient time to put alternative policies in place. But if H.R. 382 becomes law and the Title 42 restrictions end precipitously, Congress will effectively be requiring the Administration to allow thousands of migrants per day into the country immediately without the necessary policies in place.
The Administration strongly opposes enactment of H.R. 382 and H.J. Res. 7, which would be a grave disservice to the American people.
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Access to Emergency Medical Services in Rural Communities: Policy Brief and Recommendations to the Secretary
Provides an overview of issues related to the provision of emergency medical services (EMS) in rural areas. Discusses rural EMS access, financing, and workforce challenges, as well as promising telehealth innovations. Outlines federal programs and resources that support EMS programs. Offers policy recommendations related to access to EMS, workforce, and reimbursement.
From: Centers for Medicare & Medicaid Services Date: January 18, 2023 at 8:01:13 AM EST
Measure Development Education
& Outreach Series Announcement
2023 CMS MMS Public Webinars
From Data to Action: How CMS and its Stakeholders are Addressing
Inequities in Healthcare
The Centers for Medicare & Medicaid Services (CMS) is pleased to invite the public to attend the upcoming webinar “From Data to Action: How CMS and its Stakeholders are
Addressing Inequities in Healthcare.” Join us for a discussion of the CMS Health Equity Framework and how key stakeholders are leveraging changes in data science and quality measurement to drive progress toward more equitable care for all.
Tuesday, February 28, 2023, from 3 – 4:00 p.m. (ET) (Register here)
Wednesday, March 8, 2023, from 12 – 1:00 p.m. (ET) (Register here)
The first meeting (virtual) of the Ground Ambulance and Patient Billing Advisory Committee scheduled for January 17 and 18 has been postponed. According to CMS, the meeting is being postponed due to “operational impediments”. We will let you know the new dates for the meeting when announced by CMS.
The AAA has sent a letter to VA Secretary Denis McDonough asking him to delay the implementation of a final rule that would allow the Department of Veterans Affairs (VA) to reimburse at the lower of billable charges or Medicare rates for certain non-contracted ambulance services. The proposed rule was issued back in 2020 but we understand that the VA could now issue the final rule in January 2023. GMR has been advocating on Capitol Hill for a delay in air and ground ambulance services. The AAA will be issuing later today a request for AAA members to reach out to the VA to also request the delay.
December 12, 2022
The Honorable Denis McDonough
Secretary of Veterans Affairs
U.S. Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420
Dear Secretary McDonough,
The American Ambulance Association (AAA) respectfully requests that the Department delay release and implementation of the final rule on the “Change in Rates VA Pays for Special Modes of Transportation (RIN 2900-AP89).” Reimbursing for services to veterans at Medicare rates would have dire consequences for the ability of ground ambulance service organizations to provide lifesaving 9-1-1 emergency and also interfacility ambulance services not only to veterans but entire communities. We ask that the Department delay the rule until after Congress has had an opportunity to act on the results from the Medicare ambulance data collection system which is currently underway.
As documented by the Government Accountability Office (GAO) in 2007 and 2012, the Medicare program reimburses ground ambulance service organizations below the cost of providing their services when temporary add-ons are not considered. Since 2012, the disparity between the cost of providing ambulance services and reimbursement by Medicare has only increased through sequestration cuts, a reduction in inflation updates, and other Medicare payment policy changes. Ground ambulance service organizations are already facing difficult financial straits and cannot
sustain a reduction in reimbursement from another federal payor.
Ground ambulance service organizations serve as the foundation for emergency medical response for veterans and communities throughout the country. Our members are a vital component of our local and national health care and 9-1-1 emergency response systems and serve as lifelines of medical care for many rural and underserved communities. However, our ability to continue to serve communities is already at risk due to inadequate reimbursement and access to care for veterans would be further jeopardized if the Department were to reimburse at lower levels for ground ambulance services.
The AAA is the primary association for ground ambulance service organizations, including governmental entities, volunteer services, private for-profit, private not-for-profit, and hospital-based ambulance services. Our members provide emergency and non-emergency medical transportation services to more than 75 percent of the U.S. population. AAA members serve
patients in all 50 states and provide services in urban, rural, and super-rural areas.
Again, we request that you delay the release and implementation of the final rule on the “Change in Rates VA Pays for Special Modes of Transportation”.
If you have any questions regarding our request, please do not hesitate to have a member of your staff contact AAA Senior Vice President of Government Affairs Tristan North. Tristan can be reached by phone at (202) 802-9025 or email at tnorth@ambulance.org.
The Centers for Medicare & Medicaid Services (CMS) today appointed American Ambulance Association President Shawn Baird to the Ground Ambulance and Patient Billing Advisory Committee (GAPBAC), established by the Congress under “The No Surprises Act.” Shawn will represent the ground ambulance service provider and field personnel community.
“I am honored to have the opportunity to serve,” stated Baird. “I look forward to representing the interests of EMS providers and professionals as they care for our communities.
The Congress recognizes that the one-size-fits all approach to addressing surprise medical bills would not work for EMS. State and local governments regulate EMS agencies services and rates, as both first responders and medical care providers, which adds another level of complexity. As a result, the Congress established GAPBAC so the unique characteristics of ground ambulance services could be taken into consideration when evaluating private insurer billing policies to protect access to EMS, respect state and local government regulation, and protect patients.
Patients with private insurance should not be caught in the middle when their insurers do not adequately reimburse for vital ground ambulance services,” said Baird. “EMS must receive fair reimbursement by insurance companies for providing critical medical services to patients.”
Baird will bring to the Committee his years of firsthand experience and expertise as a paramedic and operator of an ambulance service in both urban and rural areas. He will also share knowledge gained from his years of volunteer leadership at the American Ambulance Association and the Oregon State Ambulance Association, as well as his term as an appointee to the National EMS Advisory Committee.
The GAPBAC is charged with “reviewing 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.” The Committee will submit a report that includes recommendations with respect to disclosure of charges and fees for ground ambulance services and insurance coverage, consumer protection and enforcement authorities of the Departments of Labor, Health and Human Services, and the Treasury and State authorities, and the prevention of balance billing to consumers. The report must be received no later than 180 days after the date of its first meeting.
About the American Ambulance Association
The American Ambulance Association safeguards the future of mobile healthcare through advocacy, thought leadership, and education. AAA advances sustainable EMS policy, empowering our members to serve their communities with high-quality on-demand healthcare. For more than 40 years, we have proudly represented those who care for people first.
