Submit Comments: EMS Compact Draft Rules
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GADCS Year 1 & Year 2 Cohort Analysis Released
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OSHA | Public Comment Period is Reopened for the Proposed Emergency Response Rule
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CISA | Hurricane Milton Access Coordination Request
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NEMSAC | Applications Open
National Emergency Medical Services Advisory Council; Solicitation of Applications
NHTSA is soliciting applications for appointment to the DOT’s NEMSAC. The purpose of NEMSAC is to serve as a nationally recognized council of Emergency Medical Services (EMS) representatives and consumers to provide advice and recommendations regarding EMS to DOT. Through NHTSA, NEMSAC’s advice is provided to the Federal Interagency Committee on EMS (FICEMS). Deadline: November 1, 2024
InvestigateTV | Dire delays at hospital ERs create long waits for ambulance crews
On Hold: Dire delays at hospital ERs create long waits for ambulance crews, put patients at risk
National data shows delayed EMS crews frequently wait an hour or more before returning to service
“To look at the scope and severity of wall times nationwide, InvestigateTV obtained data from the National Emergency Medical Services Information System (NEMSIS), a program run through the National Highway Traffic Safety Administration and the University of Utah that provides a standardized method of recording and reporting information about 911 calls involving EMS.
The data, which local EMS agencies report to their respective states that in turn submit it to the national database, documents all aspects of the call, including if the ambulance crew experienced any kind of delay.”
OSHA Statement on Volunteer Agency Impact
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Federal Departments Issue Final Report and Recommendations of the GAPB Advisory Committee
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Department of Veterans Affairs Announces Extended Timely Filing Period for Claims Impacted by Change Healthcare Cyberattack
On August 22, 2024, the Department of Veterans Affairs (VA) published a notice in the Federal Register announcing an extension of the timely filing limits for claims impacted by the Change Healthcare cyberattack.
In February, Change Healthcare announced that it was the victim of a massive cyberattack. In response, Change Healthcare proactively took down several of its online platforms, including its online claim submission platform. This platform is used by the VA to receive electronic claims. The VA indicated that this resulted in what it calls “limited or no ability” to receive electronic claims between February 21, 2024 and May 8, 2024 (referred to hereinafter as the “Limited Access Period”).
The current notice is intended to address problems with timely filing that resulted from that Limited Access Period. Specifically, the VA is announcing that claims that would have been considered timely had they been submitted during the Limited Access Period will continue to be treated as timely filed to the extent they are submitted on or before October 31, 2024.
Claims submitted after that date will not be considered timely filed, and will be denied.
Thus, the VA is effectively extending the timely filing period for VA claims through October 31, 2024. The VA expressly noted that this would include claims for transportation furnished to veterans with dates of service between February 21, 2022 and March 23, 2024. Note: the specific program under which ambulance transportation claims are being paid will determine the actual timely filing limits. The VA was simply noting the earliest and latest possible qualifying dates.
Therefore, if you have claims for ambulance services that were recently denied by the VA for lack of timely filing, the AAA encourages you to resubmit those claims to the VA under this extending timely filing period.
GAPBAC Balance Billing Report Released to Congress
Read Full GAPBAC Report to Congress
A Message from GAPBAC Committee Member Shawn Baird
Please see below for a video message from former American Ambulance Association President Shawn Baird, who participated on the Ground Ambulance Patient and Billing Advisory Committee. A formal analysis of the complete report to Congress is forthcoming.
Video Transcript
Hello, I’m Shawn Baird, past president of the American Ambulance Association.
Together with my fellow ambulance profession representatives Ted Van Horne, Regina Crawford, and Rhonda Holden, I was privileged to speak on behalf of AAA members and the EMS profession as a whole during the deliberations of the Ground Ambulance and Patient Billing Advisory Committee, also known as GAPBAC.
Today, I’m excited to share with you the culmination of our efforts—the release of a report to Congress that could transform how ground ambulance services are reimbursed, ensuring better protection for patients against surprise medical bills as well as fair compensation for the essential mobile healthcare we deliver daily.
We know that the patient care and transport we provide every day, 24/7, is vital to the health and welfare of our communities. In many parts of the country, we are the only healthcare available within hours. I am excited that if Congress acts on these recommendations, patients can not only continue to depend on our vital care, but also be relieved of the financial stress of the unknown bill when insurance falls short of appropriate payment. Quite frankly, if adopted by Congress, these recommendations would take patients out of the middle between providers and insurers, and free us to remain focused on what we do best; taking care of patients, 24/7.
Let me rewind a bit and give you the full context for this report.
GAPBAC was formed following the American Ambulance Association’s successful advocacy efforts to carve ground ambulance services out of the No Surprises Act. Through the dedication of AAA volunteer leaders made possible by your dues investment, we were able to successfully educate legislators about the unique nature of EMS. We effectively highlighted our inability to pick and choose patients, our role as the safety net provider in rural and medically underserved urban areas, as well as our sky-high costs of readiness. Instead of rolling ambulance services into a one-size-fits-all healthcare billing scheme that wouldn’t work for EMS, legislators had the vision and foresight to create the GAPBAC committee.
The group’s charter was signed in November 2021, and the roster was announced in December 2022. We are proud that former American Ambulance Association board member Asbel Montes was selected to take the helm as Chair.
Since then, our committee, composed of patient advocates, physicians, EMS experts, government officials, and insurance industry representatives, has worked collaboratively to address a critical issue—out-of-network billing for ground ambulance patients covered by non-ERISA health plans.
This discussion presented an extraordinary challenge as ambulance services face skyrocketing costs, flat reimbursement from Medicare, and an unprecedented workforce shortage. At the same time, our patients were sometimes confused by the complex health insurance landscape including copays, deductibles, and policy limitations.
But the GAPBAC panel, with the help of experts including AAA’s own Kathy Lester, persevered. Through research, dialogue, and compromise, GAPBAC’s team members developed 14 key recommendations that, if adopted by Congress, would protect patients, financially sustain EMS, enhance transparency, and empower state and local governments to determine fair reimbursement rates for their residents.
While I urge you to read the report to Congress in its entirety, rest assured that the AAA advocacy team will soon share a concise summary with our membership.
As I mentioned, the release of this report has been no small task. The collaboration across various stakeholder groups was unprecedented in EMS history, and every voice brought valuable insights, driving us toward solutions that consider all perspectives on the complex mobile healthcare reimbursement landscape. Together, we’ve laid down a framework that I believe will lead to significant improvements, ensuring that millions more Americans are fully covered during some of the most critical moments of their lives.
As we present our final findings, I hope that the recommendations will be met with thoughtful consideration by Congress and regulators—the well-being of our patients and the integrity of our out-of-hospital healthcare system depend on it. Thank you to American Ambulance Association President Strozyk, the AAA board and committee chairs, and you, the AAA membership, for the overwhelming support through this journey. Together, we will continue to advocate for a sustainable future for EMS!
Shawn Baird
Immediate Past President
American Ambulance Association
Preliminary Calculation of 2025 Ambulance Inflation Update
The AAA is projecting that the 2025 Medicare Ambulance Inflation Factor will likely be 2.6%, plus or minus 0.1%.
Section 1834(l)(3)(B) of the Social Security Act mandates that the Medicare Ambulance Fee Schedule be updated each year to reflect inflation. This update is referred to as the “Ambulance Inflation Factor” or “AIF”.
The AIF is calculated by measuring the increase in the consumer price index for all urban consumers (CPI-U) for the 12-month period ending with June of the previous year. Starting in calendar year 2011, the change in the CPI-U is now reduced by a so-called “productivity adjustment”, which is equal to the 10-year moving average of changes in the economy-wide private nonfarm business multi factor productivity index (MFP). The MFP reduction may result in a negative AIF for any calendar year. The resulting AIF is then added to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.
For the 12-month period ending in June 2024, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 3.0%.
CMS has yet to release its estimate for the MFP for calendar year 2024. Since its inception, this number has fluctuated between 0.3% and 1.2%. For calendar year 2024, the MFP was 0.4%.
Under normal circumstances, it would be reasonable to expect the 2025 MFP to be within a tenth of a percentage point or two of the 2024 MFP.
Accordingly, the AAA is projecting that the 2025 Ambulance Inflation Factor will likely be 2.6%, plus or minus 0.1%.
The AAA will notify members once CMS issues a transmittal setting forth the official 2025 Ambulance Inflation Factor.
OSHA Announces Public Hearing on the Proposed Emergency Response Rule
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EMS.gov | Responding to Behavioral Health Emergencies
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CMS Publishes Two New Reports on GADCS Website
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| Dear Ground Ambulance Providers and Suppliers,
We wanted you to be aware that we posted 2 reports on our Medicare Ground Ambulance Data Collection System website under Reports: |
What The Guardian Missed About US Ambulance Balance Billing
Media Response
The letter to the editor below was submitted to The Guardian on July 23, following the July 21 publication of the article referenced.
To the Editor of The Guardian,
On July 21, The Guardian published Jessica Glenza’s “Plan to end exorbitant ‘surprise’ ambulance bills heads to Congress.” The inflammatory title and lack of context do no justice to the years of bipartisan collaborative effort leading to the forthcoming report to Congress. As a member of the Advisory Committee on Ground Ambulance and Patient Billing (GAPB) and Immediate Past President of the American Ambulance Association, I believe it is critical to set the record straight.
It is essential to understand that EMS directly bills patients instead of insurers only as a last resort. Sadly, as a frequent entry point to healthcare, EMS often faces the unenviable task of educating people about their limited insurance coverage or high deductibles, both of which are out of our control. As mobile healthcare is entirely decentralized in the United States, it is often unfeasible for small or volunteer-staffed ambulance services to negotiate sustainable in-network rates with dozens of insurance plans. The GAPB Advisory Committee’s recommendations seek to remedy this foundational disconnect between patients, EMS providers, and health plans.
The article notes that some EMS providers are owned by private equity, but overlooks that the vast majority of ambulance services in the United States are small, often conducting only a few dozen patient transports per day. These community-based services—some of which are the sole healthcare provider for miles—face skyrocketing costs for wages, fuel, and medical supplies that threaten their ability to keep their doors open. The collaborative work of the GAPB Advisory Committee sought to address these challenges by proposing recommendations that, if adopted by Congress, would help alleviate these financial pressures while also enhancing patient protection from surprise insurance denials.
The article implies that Patricia Kelmar was the only representative of the public interest on the panel. In fact, another Committee participant was explicitly appointed to represent patient advocacy groups, and as healthcare providers, EMS professionals and physicians consistently advocate for our patients’ well-being. The committee’s composition, as established by Congress within the No Surprises Act, was intentionally diverse and included stakeholders ranging from physicians to elected officials to insurance providers to ensure balance.
Additionally, it is important to clarify that the Health Affairs research cited in the article does not provide data on actual balance bills received by patients. Rather, it roughly estimates only potential balance bills as calculated based on a flawed estimation process. Even if we were to accept Health Affairs estimates as fact, the average balance bill calculated according to their methods would be just a few hundred dollars. This is far from the sole and extreme outlier bill cited in the piece. This distinction is critical as it underscores the need for data-driven policy decisions based on real-world evidence rather than projections and one-off examples.
Finally, the piece misses entirely the largest challenge with the Committee’s recommendations and their potential adoption by Congress. Based on longstanding legal precedent, ERISA plans, which cover about half of Americans through their employers, would not be bound by any legislation drafted based on our report. In Washington state and elsewhere, innovative “opt-in” clauses enable ERISA plans to voluntarily comply with state regulation. We encourage this and hope to see it replicated throughout the nation.
People become first responders because they have a passion for caring for others, and our communities trust them to do just that—24/7. Our Committee’s report to Congress includes 14 key recommendations designed to improve transparency, ensure fair reimbursement rates, and ultimately protect patients by strengthening state and local control. If these recommendations are adopted, they will help remove patients from the middle of billing disputes, allowing EMS providers to focus on our primary mission: delivering life-saving and life-sustaining healthcare around the clock.
For a detailed understanding of our recommendations and the Committee’s work, I encourage reading the full GAPB Advisory Committee report when it becomes available later this summer.
Shawn Baird
Immediate Past President, American Ambulance Association
Member, Advisory Committee on Ground Ambulance and Patient Billing
Portland, Oregon
Treatment In Place Bill Introduced in House
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2024 Ambulance Ride-Along Toolkit
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OSHA NPRM Emergency Response Standard 2nd Comment Period Extension
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OSHA Emergency Response Rule Comment Period Extended Again
From the OSHA Website on June 4, 2024
NEW Update: The deadline for comment submission has been extended a second time to July 22, 2024.
The Emergency Response proposed rule is here!
OSHA is happy to announce that the Emergency Response proposed rule has been published in the Federal Register and is now available for viewing.
OSHA welcomes and encourages the submission of public comments in response to this proposed rule. To allow additional time for those individuals interested in creating and submitting a comment, OSHA will be further extending the window for comment submission. The comment period now ends on July 22, 2024.
Comments can be submitted to the Emergency Response Docket at https://www.regulations.gov/docket/OSHA-2007-0073.
OSHA will also be hosting a public hearing, the date of which has yet to be determined. To ensure access to the hearing for all interested members of the public, remote access will be provided.
Additional information on OSHA’s rulemaking process and how stakeholders can participate is available at https://www.osha.gov/laws-regs/rulemakingprocess.
AAA Submits Paramedic Expedited Visa Comments in Line with PARA-EMT Act
On May 13, the AAA submitted a Comment Letter to the Department of Labor (DOL) in response to their Request for Information (RFI) on modernizing the process and updating the occupations that fall under the Schedule A program. Schedule A is a program administered by DOL which allows for expedited visa processing for occupations with a predetermined workforce shortage. The AAA advocated in our letter for the DOL to add paramedics and EMTs to Schedule A which currently includes nurses, physical therapists and individuals with exceptional abilities in the sciences and arts.
The comment letter by the AAA is in line with a provision of the PARA-EMT Act (H.R. 6433) by Congresswoman Gluesenkamp Perez (D-WA) and Congressman Brad Finstad that would direct DOL to conduct a study on the EMS workforce shortage and report to Congress on consideration by the Department to add paramedics and EMTs to the list of occupations under Schedule A.