CAAS Releases GVS V4.0 Draft for Public Comment #2
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The Honorable Brett Guthrie
Chair
Committee on Energy and Commerce
United States House of Representatives
2161 Rayburn House Office Building
Washington, DC 20515
The Honorable Buddy Carter
Chair
Energy and Commerce Subcommittee on Health
United States House of Representatives
2432 Rayburn House Office Building
Washington, DC 20515
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
United States House of Representatives
2107 Rayburn House Office Building
Washington, DC 20515
The Honorable Dianna DeGette
Ranking Member
Energy and Commerce Subcommittee on
Health
United States House of Representatives
2111 Rayburn House Office Building
Washington, DC 20515
Re: Medicaid Supplemental Payments for Ground Ambulance Services
Dear Chair Guthrie, Ranking Member Pallone, Chair Carter, and Ranking Member DeGette,
On behalf of 31 state ambulance and emergency medical services (EMS) associations, we ask for your continued support for Medicaid supplemental payment programs that provide critical support to EMS providers.
Ambulance service providers face financial pressures and risk closure at an alarming rate in every state. In rural communities in particular, EMS providers are often the only healthcare providers delivering care for hundreds of miles. Medicaid supplemental payment programs offer transparent and sustainable ways to support first responders, allowing them to continue providing life-saving services, train paramedics, and ensure our rural communities are not left without care.
The most at-risk ambulance service providers—those serving rural communities—face unique challenges including large coverage areas, increased travel distances, and higher costs per transport. Adequate support for staffing, training, and equipment is already a major challenge. Medicaid supplemental payment programs focus on improving rural access to care by driving dedicated resources to those communities.
We are deeply concerned by recent proposals that would severely reduce critical Medicaid reimbursement by reducing provider assessments and mandating the use of artificial caps on supplemental payments that would prevent rates from covering costs.
EMS and ambulance service providers, rural hospitals, and safety-net health clinics will close without continued funding that Medicaid supplemental payment funds provide.
Our ambulance associations are eager to collaborate with the Congress and the Administration on solutions that sustain Medicaid financing and ensure ambulance service providers continue to meet the needs of their communities. We appreciate the opportunity to engage in further discussion and provide data on how these programs directly affect each of our states.
Sincerely,
Alabama Association of Ambulance Services
Arkansas Ambulance Association
California Ambulance Association
EMS Association of Colorado
Georgia Ambulance Providers Association
Kentucky Ambulance Providers Association
Louisiana Ambulance Alliance
Massachusetts Ambulance Association
Michigan Association of Ambulance Services
Minnesota Ambulance Association
Mississippi Ambulance Alliance
Missouri Ambulance Association
Montana Ambulance Association
Nevada Ambulance Association
New Hampshire Ambulance Association
Medical Transportation Association of New Jersey
United New York Ambulance Network
Ohio Ambulance & Medical Transportation Association
Oklahoma Ambulance Association
Oregon State Ambulance Association
Ambulance Association of Pennsylvania
South Carolina EMS Association
Tennessee Ambulance Service Association
Texas Ambulance Association
Texas EMS Alliance
Vermont Ambulance Association
Virginia Ambulance Association
Washington Ambulance Association
West Virginia EMS Coalition
Professional Ambulance Association of Wisconsin
Wyoming EMS Association
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orOn December 23, 2024, CMS posted a revised version of the CY 2025 Ambulance Fee Schedule Public Use Files on its website. These files contain the Medicare allowed amounts for the various levels of ambulance service and mileage. The file is organized by state, and by payment locality within each state. The 2025 Ambulance Fee Schedule Public Use File can be viewed by clicking here.
Unfortunately, CMS has elected in recent years to release its Public Use Files without state and payment locality headings. As a result, in order to look up the rates in your service area, you would need to know the CMS contract number assigned to your state. This is not something the typical ambulance service would necessarily have on hand. For this reason, the AAA has created a reformatted version of the CMS Medicare Ambulance Fee Schedule, which includes the state and payment locality headings. Members can access this reformatted fee schedule below.
The American Ambulance Association is also pleased to announce the release of its 2025 Medicare Rate Calculator tool. The AAA believes this is a valuable tool that can assist members in budgeting for the current year. This calculator has been updated to account for recent changes in Medicare policies, including the 2025 Ambulance Inflation Factor and the extension of the temporary adjustments for ground ambulance services (i.e., 2% urban, 3% rural, and super rural bonus) through March 31, 2025. This extension was the result of Section 3203 of the American Relief Act, 2025. Barring further legislation, these temporary adjustments will expire on March 31, 2025.
Note on Medicare Sequestration: Both the Ambulance Fee Schedule Public Use Files and the AAA Medicare Rate Calculator display the current Medicare allowables. Neither takes into account the impact of so-called “budget sequestration” on Medicare payments. By law, the sequester requires Medicare contractors (and Medicare Advantage insurers) to reduce the amounts they pay under the Medicare Ambulance Fee Schedule by 2% (i.e., 2% off the 80% of the Medicare allowable typically paid by the Medicare contractor).
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orNHTSA 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
“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.”
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orOn 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.
Read Full GAPBAC Report to Congress
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.
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
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.
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