OSHA Updates & Reminders 2018

It is important that employers remember that they must post a copy of their OSHA Form 300A which is a summary of workplace injuries starting February 1, 2018 through April 30, 2018.  The OSHA Form 300A is a summary of all job-related injuries and illnesses that occurred in an employer’s workplace during 2017.  If a company recorded no injuries or illnesses in 2018, the employer must enter “zero” on the total line. The form must be signed and certified by a company executive. The OSHA Form 300A Injury Summary must be displayed in a common area where notices to employees are usually posted.  In addition to posting these reports in the workplace, covered employers will have to electronically report their injury data on the Injury Tracking Application (ITA) by July 1, 2018. Also, a reminder to employers who are subject to OSHA or to those who operate in a state with an OSHA approved state level plan, the penalty amounts for OSHA violations are increasing effective January 2, 2018.  In accordance with the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the Department of Labor is required to adjust penalties for inflation each year. New penalties for willful...

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President’s Perspective: October 2017

Dear Fellow AAA Members, As I reflect on the past few months, I am awed by the dedication of ambulance services across the nation as they responded to emergencies ranging from hurricanes to wildfires to the Las Vegas MCI. As always, EMS aided their communities with humanity, efficiency, and deep-rooted professionalism. The outcomes of each of these incidents would assuredly have been far worse without the selfless service of our fellow healthcare providers. I was privileged to see this commitment to excellence firsthand as our staff at Sunstar responded to Hurricane Maria here in Florida, assisted by hundreds of EMTs, Paramedics, and strike team leaders who drove hours or days to help. Thanks to each of you for your service in our country’s time of need. Advocacy Update The AAA continues working hard to ensure the Medicare add-on payments don’t expire at the end of this year. In the Senate, S. 967 would make the add-on payments permanent. In the House, two versions of a bill (H.R. 3236, H.R. 3729) would extend the payments for five years. Extensions of Medicare provider provisions, including the ambulance add-on payments, will likely be addressed closer to the end of the year. We have...

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Is the TX Moratorium Ending?

Is CMS Ending the Temporary Moratorium on Enrollment of New Non-Emergency Ground Ambulance Providers in Texas? On September 2, 2017, the Centers for Medicare and Medicaid Services (CMS) posted a notice on its website that it was lifting the temporary moratorium on the enrollment of new Part B non-emergency ambulance suppliers in Texas, effective September 1, 2017.  CMS indicated that the lifting of this temporary moratorium was intended to aid in the disaster response to Hurricane Harvey. For reasons I will discuss in greater detail below, this explanation has struck a number of commentators as curious.  These commentators have speculated that this may notice may foretell a permanent elimination of the enrollment moratorium for non-emergency ground ambulance providers in Texas. Background on Temporary Moratorium on New Enrollments in Texas The Affordable Care Act granted CMS several new tools to combat fraud, waste, and abuse in the Medicare, Medicaid, and Children’s Health Insurance Programs.  This included Section 6401(a), which granted the CMS Secretary the authority to impose temporary moratoria on the enrollment of new Medicare, Medicaid, or CHIP providers to the extent the Secretary determined that doing was necessary to prevent fraud and abuse. The implementation of the first enrollment moratorium...

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Trump Administration Interim HHS Rule

In a surprising announcement by the Trump Administration late Friday, the Department of Health and Human Services (HHS) the Administration released an interim rule that rolled back the Obama Administration rules regarding the requirement of employer sponsored health plans to pay for “preventative services” which included birth control and abortion procedures under religious or moral objections. The move has initiated legal action by the Attorney General in Massachusetts who announced yesterday that she has filed a suit in U.S. District Court yesterday. Key facts about the interim final rules: The regulations exempt entities only from providing an otherwise mandated item to which they object on the basis of their religious beliefs or moral conviction. The regulation leaves in place preventive services coverage guidelines where no religious or moral objection exists. The Administration is asserting that out of millions of employers in the U.S., these exemptions would only impact about 200 entities. Current law itself already exempts over 25 million people from the preventive-care mandate because they are insured through an entity that has a health insurance plan that existed prior to the Obamacare statute. The regulations leave in place government programs that provide free or subsidized contraceptive coverage to low income...

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EMS.gov Ambulance Crash Data

NHTSA’s Office of EMS has partnered with a number of organizations, Federal agencies and U.S. Department of Transportation offices to develop resources that help EMS agencies understand ambulance crashes, transport patients safely, report ambulance and equipment defects and build or buy safer ambulances. Download the ambulance crash infographic► Visit the site today►

Talking Medicare: CMS Transmittal 236

On June 16, 2017, the Centers for Medicare & Medicaid Services (CMS) released Transmittal 236. This Transmittal makes some minor changes to Chapter 10 of the Medicare Benefit Policy Manual. Specifically, CMS is clarifying its definitions related to the “ALS assessment” and “locality.” The change to the locality definition has prompted some discussion within the industry as to the impact on Medicare’s reimbursement for mileage beyond the nearest appropriate facility. In this month’s blog, I will explain the recent change, and hopefully convince you that this isn’t something that should cause you undue concern. Medicare’s Definition of “Locality” The definition of “locality” appears in Section 10.3.5 of Chapter 10 of the Medicare Benefit Policy Manual. That definition reads as follows: The term “locality” with respect to ambulance service means the service area surrounding the institution to which individuals normally travel or are expected to travel to receive hospital or skilled nursing services. CMS then includes the following example to explain how that definition should be applied to real world situations: EXAMPLE: Mr. A becomes ill at home and requires ambulance service to the hospital. The small community in which he lives has a 35-bed hospital. Two large metropolitan hospitals are...

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Now On-Demand: Member Government Affairs Webinar

The American Ambulance Association (AAA) hosted the Government Affairs and Member Forum on June 29 to provide an update on legislation on the expiring temporary Medicare ambulance add-on payments, the immediate and long-term goals of AAA on Medicare reform, and how members can get involved with ambulance service-related issues. Mark Postma, president of AAA, and a panel of experts covered varied topics, including where Senate Bill S.967 stands and what changes might occur within the industry, and then fielded questions from members to offer a better understanding of regulatory issues and what’s happening in Washington. “We put a forum together at this critical time because we currently have a Senate bill to make the add-on permanent, and we’ve been working on a House bill for a long-term extension of the add-ons to be dropped soon,” said Postma. “We have been working diligently to get the appropriate bills introduced, to keep the Medicare extenders and other items that we’ll discuss in this forum.” Capitol Hill Landscape The Senate “Medicare Ambulance Access, Fraud Prevention and Reform Act” (S.967) has bipartisan support and is currently being championed Sen. Debbie Stabenow (D-MI), Pat Roberts (R-KS), Chuck Schumer (D-NY), Susan Collins (R-ME) and Patrick Leahy...

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EMS Education – A Look Forward

I have always believed EMS parallels the career trajectory of nursing. This is especially true when you look at the infancy of nursing—1750 to 1893—in what was a subservient apprenticeship with no didactic education. “Most nurses working in the States received on-the-job training in hospital diploma schools. Nursing students initially were unpaid, giving hospitals a source of free labor. This created what many nurse historians and policy analysts see as a system that continues to undervalue nursing’s contribution to acute care.” (History Lesson: Nursing Education has evolved over the decades, 2012, para. 5). We reached a turning point in 1893 when the Columbian Exposition met, and although Ms. Florence Nightingale was unavailable to attend, she did have a paper presented at the exposition. In essence, the paper proved that a well-educated nursing workforce with standards of practice was needed to improve the health care of the United States. This is exactly where EMS is now. Young enough to have moved through our growing pains of the late ’60s and early ’70s, but lucky enough to be in an age of extensive medical growth where all levels of providers are looking to enhance the care being provided. So where do we...

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