EMS.gov | NEMSAC Members Appointed
From EMS.gov on October 6
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CMS | Open Door Forum on Prior Authorization for RSNAT
From CMS on October 5, 2021
Centers for Medicare & Medicaid Services Center for Medicare and Medicaid Innovation
Special Open Door Forum: Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model National Expansion
Thursday, October 28, 2021
2:00-3:30 pm Eastern Time
Conference Call Only
Participant Dial-In Number: 1-888-455-1397 | Conference ID #: 8604468
CMS will host a Special Open Door Forum (SODF) to allow ambulance suppliers, other Medicare providers, and additional interested parties to learn about the upcoming national expansion of the Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) Prior Authorization Model in Medicare fee for service. CMS is implementing the national model in multiple phases beginning with Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, and Texas on December 1, 2021. The RSNAT Prior Authorization Model is currently operating in New Jersey, Pennsylvania, and South Carolina since 2014 and in North Carolina, Virginia, West Virginia, Maryland, Delaware, and the District of Columbia since 2016. This Special ODF will include information on national expansion, the prior authorization process, and a Q&A period.
You can find more information on the model and slides for the ODF presentation by going to:
Questions on the model can be sent to: AmbulancePA@cms.hhs.gov
We look forward to your participation.
Special Open Door Participation Instructions:
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468
Note: 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.
A transcript and audio recording of this Special ODF will be posted to the Special Open Door Forum website at https://www.cms.gov/Outreach-
For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at https://www.cms.gov/Outreach-
Thank you for your interest in CMS Open Door Forums.
Congressional Letter on the EMS Workforce Shortage
October 1, 2021
The Honorable Nancy Pelosi
Speaker of the House
U.S. House of Representatives
Washington, DC 20515
The Honorable Kevin McCarthy
Minority Leader
U.S. House of Representatives
Washington, DC 20515
The Honorable Charles Schumer
Majority Leader
United States Senate
Washington, DC 20510
The Honorable Mitch McConnell
Minority Leader
United States Senate
Washington, DC 20510
Dear Speaker Pelosi, Majority Leader Schumer, Minority Leader McConnell & Minority Leader McCarthy,
Our paramedics and emergency medical technicians (EMTs), as well as the organizations that they serve, take on substantial risk every day to treat and transport patients that call 9-1-1. But our nation’s EMS system is facing a crippling workforce shortage, a long-term problem that has been building for more than a decade. It threatens to undermine our emergency 9-1-1 infrastructure and deserves urgent attention by the Congress.
The most sweeping survey of its kind — involving nearly 20,000 employees working at 258 EMS organizations — found that overall turnover among paramedics and EMTs ranges from 20 to 30 percent annually. With percentages that high, ambulance services face 100% turnover over a four- year period. Staffing shortages compromise our ability to respond to healthcare emergencies, especially in rural and underserved parts of the country.
The pandemic exacerbated this shortage and highlighted our need to better understand the drivers of workforce turnover. There are many factors. Our ambulance crews are suffering under the grind of surging demand, burnout, fear of getting sick and stresses on their families. In addition, with COVID-19 halting clinical and in-person trainings for a long period of time, our pipeline for staff is stretched even more.
The challenge is to make sure that the paramedics and EMTs of the future know that EMS is a rewarding destination. Many healthcare providers have extensive professional development resources, but that simply does not exist for EMS. COVID-19 has put additional pressures on the health care system and added another layer of complexity to the emergency response infrastructure.
HRSA EMS Training Funding
Fortunately, there are immediate and long-term solutions. Although the provider relief funds are essential and helpful to address the challenges of the pandemic, we need funding for EMS that addresses paramedic and EMT training, recruitment, and advancement more directly. The Congress can provide specific direction and funds to the Health Resources and Services Administration (HRSA) to help solve this workforce crisis. Those funds can be used to pay for critical training and professional development programs. Some of our members have already begun offering programs and would benefit from additional funding support from HRSA. Funding public-private partnerships between community colleges and private employers to increase the applicant pool and training and employment numbers through grants could overcome the staffing deficit we face.
Paramedic and EMT Direct Pay Bump
In addition, more immediately targeting funds for EMS retention could address the shortage we are experiencing day to day. To help ambulance services retain paramedics and EMTs, we request funds through HRSA to be paid directly to paramedics and EMTs. These earmarked funds could be distributed to each state with specific guidance that the State Offices of EMS distribute the funds to all ground ambulance services using a proportional formula (per field medic).
COVID-19 Medicare Reimbursement Increase
With capitated payments by federal payors, there are limited funds to transfer into workforce initiatives. Increasing Medicare payments temporarily would be meaningful to compete with other employers and other jobs. This could help infuse additional funds into the workforce and create innovative staffing models that take into account hospital bed shortages and overflow.
Congressional Hearings on EMS Workforce Shortage
The workforce shortage crisis facing EMS spans several potential Committees of jurisdiction. This critical shortage is particularly felt in many of our rural and underserved communities. As Congress moves on the steps we have outlined above, we also urge you to organize hearings in the appropriate Committees to develop long-term solutions and focus the country’s attention on these urgent issues.
Thank you in advance for continuing to ensure that our frontline responders have the resources necessary to continue caring for our patients in their greatest moment of need, while maintaining the long-term viability of our nation’s EMS system.
Thank you for your consideration. Sincerely,
Shawn Baird
President
American Ambulance Association
Bruce Evans
President
National Association of Emergency Medical Technicians
CMS | Medicare Ground Ambulance Data Collection Webinars October 7 & 12
From CMS on October 4, 2021
Dear Ground Ambulance Providers and Suppliers,
Please attend our October 7 webinar and October 12 Q&A session to learn about the Medicare Ground Ambulance Data Collection System. Both events will use Zoom. Starting January 1, 2023, selected ground ambulance organizations are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10% payment reduction.
Medicare Ground Ambulance Data Collection System Webinar: Labor Costs – October 7
Thursday, October 7 from 2-3pm ET
Register for this Zoom webinar.
During this webinar, CMS will walk through the Labor Cost section of the Medicare Ground Ambulance Data Collection Instrument (section 7). The presentation includes examples to help different types of ground ambulance organizations understand how to collect and report data for their paid and volunteer staff.
A Q&A session will follow this presentation. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 7 Labor Cost Webinar” in the subject line.
More information:
- Presentation
- Ambulances Services Center webpage–includes lists of organizations that must collect data starting in 2022
- CY 2022 Physician Fee Schedule (PFS) proposed rule
- CY 2020 PFS final rule
- Bipartisan Budget Act of 2018
Medicare Ground Ambulance Data Collection System: Q&A Session – October 12
Tuesday, October 12 from 2-3pm ET
Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 12 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.
More Information:
- Ambulances Services Center webpage –includes lists of organizations that must collect data starting in 2022
- CY 2022 Physician Fee Schedule (PFS) proposed rule
- CY 2020 PFS final rule
- Bipartisan Budget Act of 2018
Tranche 4 Application—TIN Validation Error
This content is for AAA members only.
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New Guidance on COVID-19 Workplace Safety for Federal Contractors
This week, the Safer Federal Workforce Task Force released new guidance on COVID-19 workplace safety protocols for Federal contractors and subcontractors. On September 9, President Biden signed Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal Contractors, which directed executive departments and agencies to ensure that all federal contractors and subcontractors comply with all guidance published by the Task Force. These workplace safety protocols will apply to all covered contractor and subcontractor employees in covered contractor workplaces even if they are not working on Federal Government contracts.
Overview of Workplace Safety Protocols for Federal Contractors and Subcontractors
Pursuant to the guidance issued this week, and in addition to any requirements or workplace safety protocols that are applicable because a contractor or subcontractor employee is present at a Federal workplace, Federal contractors and subcontractors with a covered contract will be required to conform to the following workplace safety protocols:
- COVID-19 vaccination of covered contractor employees, except in limited circumstances where an employee is legally entitled to a medical or religious accommodation;
- Compliance by individuals, including covered contractor employees and visitors, with the Guidance related to masking and physical distancing while in covered contractor workplaces; and
- Designation by covered contractors of a person or persons to coordinate COVID-19 workplace safety efforts at covered contractor workplaces.
The guidance provides details regarding who is included under these new rules. Under the latest guidance, a “Covered Contractor Employee” means any full-time or part-time employee of a covered contractor” working on” or “in connection with” a covered contract or working at a covered contractor workplace. This includes employees of covered contractors who are not themselves working on or in connection with a covered contract, except for those employees who only perform work outside the United States or its outlying areas. This means that all ambulance service employees, who perform work related to or in connection with the contract, such as dispatchers, human resource and billing personnel, training staff, etc. are subject to the new requirements. This includes employees working from remotely or from home, who are performing work in connection with the contract.
Under the guidance, a “Covered Contractor Workplaces” are locations controlled by a covered contractor at which any employee of a covered contractor working on or in connection with a covered contract is likely to be present during the period of performance for a covered contract. This includes those workplaces such as ambulance stations, administrative offices, etc.
Vaccination of Covered Contractor Employees
Covered contractors must ensure that all their covered employees are fully vaccinated for COVID-19 unless the employee is legally entitled to an accommodation. Covered contractor employees must be fully vaccinated no later than December 8, 2021. The guidance detailed that vaccination is required of all employees, even if they have previously been infected with COVID-19.
Proof of COVID-19 Vaccination
Under this guidance, the contractor or subcontractor must review the covered employee’s documentation to prove vaccination status. The guidance identifies the list of acceptable documents an employee can furnish to prove vaccination, including:
- Copy of Immunization Record from a healthcare provider or pharmacy
- Copy of the COVID-19 Vaccination Record Card (CDC Form MLS-319813_r, published 9/3/2020)
- Copy of Medical Records documenting the vaccination
- Copy of Immunization Records from a public health or State Immunization Information System
- Copy of any other official documentation verifying vaccination with information of:
- Vaccine name
- Date of administration
- Name of healthcare professional or clinic site administering the vaccine
*Digital copies of these records are acceptable (jpg, scanned PDF, etc.)
The guidance specified that a signed attestation by the employee is not acceptable proof of vaccination. Additionally, the guidance stated that recent COVID-19 antibody tests do not satisfy the requirements under these rules.
Masking and Physical Distancing While in Covered Contractor Workplaces
Covered contractors must ensure that all individuals, including covered contractor employees and visitors, comply with published CDC guidance for masking and physical distancing at a covered contractor workplace. The guidance provided more details on these masking and physical distancing requirements. These include requiring unvaccinated individuals to mask indoors and in certain outdoor settings regardless of COVID-19 transmission levels. Contractors are required to monitor the community transmission levels on the CDC COVID-19 Data Tracker County View website on a weekly basis.
COVID-19 Coordinator Designation
Covered contractors must designate a person or persons to coordinate implementation of, and compliance with, these workplace safety protocols at covered contractor workplaces. Their responsibilities to coordinate COVID-19 workplace safety protocols may comprise some or all of their regular duties. This individual can be the same person who is designated under other state or local COVID-19 safety requirements.
Finally
The guidance makes it clear that the rules applicable to all federal contractors and supersedes any state or local rules or regulations that are contrary to these provisions. That means that any rules that prohibit mask or other COVID-19 related safety mandates, or otherwise contradict the rules under this guidance will not excuse a federal contractor’s obligations under these rules.
The guidance will be finalized by the Office of Management & Budget in the coming days. In the meantime, if you have any questions or need assistance, contact the AAA at hello@ambulance.org.
Application Open: COVID-19 Provider Relief Funding
From HHS on September 29, 2021
The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced a new application cycle for $25.5 billion in COVID-19 provider funding. Applicants will be able to apply for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments during the application process. PRF Phase 4 is open to a broad range of providers with changes in operating revenues and expenses. ARP Rural is open to providers who serve rural patients covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).
See a detailed list of eligible provider types here.
The application is open now and will close on October 26, 2021 at 11:59 p.m. ET. Providers who have previously created an account in the Provider Relief Fund Application and Attestation Portal and have not logged in for more than 90 days will need to first reset their password before starting a new application. In order to streamline the application process and minimize administrative burdens, providers will apply for both programs in a single application.
HHS recently hosted a briefing session to provide information about these upcoming funding opportunities – view the video here. HRSA will also host webinar sessions featuring guidance on how to navigate the application portal. Register now using the links below.
- Thursday, September 30 from 3:00 – 4:00 p.m. ET
- Tuesday, October 5 from 3:00 – 4:00 p.m. ET
- Two additional webinars the weeks of October 11th and 18th (dates, times, and registration forthcoming)
Real time technical assistance is available by calling the Provider Support Line at (866) 569-3522, for TTY dial 711. Hours of operation are 8 a.m. to 10 p.m. CT, Monday through Friday.
HHS PRF Tranche 4 | Important Funding Opportunity for EMS Providers
Speaker: Scott Moore, Esq. | Share on Facebook
This funding opportunity will distribute $25.5 billion in additional Phase 4 General Distribution for EMS agencies and American Rescue Plan (ARP) payments for qualified rural providers who furnish services to Medicaid/CHIP and Medicare beneficiaries. It is critical for all #EMS providers to apply for this funding opportunity regardless of previous funding allocations. We have learned that many EMS providers did not apply for the Tranche 3 funding opportunity because they did not believe that they would be eligible to receive funds under the announced funding formula. Due to the limited number of applicants in Tranche 3, HRSA modified the formula and many who failed to apply would have received funds. We are recommending that all EMS agencies apply to receive the funding that they desperately need. The deadline for applying is 11:59 p.m. on October 26, 2021. There is no penalty for applying.
CMS Will Pay for COVID-19 Booster Shots, Eligible Consumers Can Receive at No Cost
From CMS on September 24, 2021
CMS Will Pay for COVID-19 Booster Shots, Eligible Consumers Can Receive at No Cost
Coverage without cost-sharing available for eligible people with Medicare, Medicaid, CHIP, and Most Commercial Health Insurance Coverage
Following the Food and Drug Administration’s (FDA) recent action that authorized a booster dose of the Pfizer COVID-19 vaccine for certain high-risk populations and a recommendation from the Centers for Disease Control and Prevention (CDC), the Centers for Medicare & Medicaid Services (CMS) will continue to provide coverage for this critical protection from the virus, including booster doses, without cost sharing.
Beneficiaries with Medicare pay nothing for COVID-19 vaccines or their administration, and there is no applicable copayment, coinsurance or deductible. In addition, thanks to the American Rescue Plan Act of 2021 (ARP), nearly all Medicaid and CHIP beneficiaries must receive coverage of COVID-19 vaccines and their administration, without cost-sharing. COVID-19 vaccines and their administration, including boosters, will also be covered without cost-sharing for eligible consumers of most issuers of health insurance in the commercial market. People can visit vaccines.gov (English) or vacunas.gov (Spanish) to search for vaccines nearby.
“The Biden-Harris Administration has made the safe and effective COVID-19 vaccines accessible and free to people across the country. CMS is ensuring that cost is not a barrier to access, including for boosters,” said CMS Administrator Chiquita Brooks-LaSure. “CMS will pay Medicare vaccine providers who administer approved COVID-19 boosters, enabling people to access these vaccines at no cost.”
CMS continues to explore ways to ensure maximum access to COVID-19 vaccinations. More information regarding the CDC COVID-19 Vaccination Program Provider Requirements and how the COVID-19 vaccine is provided through that program at no cost to recipients is available at https://www.cdc.gov/
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EMS.gov | EMS Medical Director Survey
EMS and 911 Physician Medical Directors Invited to Participate in Workforce Assessment Survey
National Association of EMS Physicians conducting a national, anonymous survey of EMS, 911, fire and law enforcement medical directors
The National Association of EMS Physicians (NAEMSP) is conducting the first national EMS Physician Medical Directors Workforce Assessment in the United States. All physician medical directors for EMS and air medical services, 911/Emergency Medical Dispatch centers, fire services, and law enforcement departments are encouraged to complete this anonymous survey to help create a comprehensive picture of pre-hospital physician medical leadership. The survey will take approximately 10 minutes to complete and will close on October 4, 2021.
The results, which will be shared by NAEMSP, will help national, state and local EMS and 911 organizations identify physician employment trends, address training and professional needs, and inform policy and advocacy efforts in support of all prehospital medical directors.
“Thousands of physician EMS Medical Directors currently provide EMS system oversight to ensure high-quality, safe and effective patient care across the country,” says NAEMSP President Michael Levy, MD, FAEMS, FACEP, FACP. “It’s important that we get an accurate picture of physician medical directors’ professional needs so we can do our best to address them.”
“The role of the medical director is key in ensuring effective pre-hospital patient care,” says Jon Krohmer, MD, FACEP, FAEMS, director of the NHTSA Office of EMS. “More data about the many aspects of medical direction will help NAEMSP, the NHTSA Office of EMS, and our Federal partner agencies better engage with the physicians who guide first responder and EMS clinician patient interactions by ground, air medical, law enforcement, and 911 professionals.”
HRSA Announces 60-Day Grace Period for Provider Relief Fund Reporting
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CMS | National Stakeholder Call with the Administrator
You are invited to join the Administrator of the Centers for Medicare & Medicaid Services’ (CMS), Chiquita Brooks-LaSure, and her leadership team, to hear key updates from her first 100 days in office. The Administrator’s vision is for CMS to serve the public as a trusted partner and steward, dedicated to advancing health equity, expanding coverage, and improving health outcomes. We invite you to join us for this first national stakeholder call to learn more about how you can partner with us as we implement our vision.
When: September 17, 2021 from 12:30 PM ET – 1:00 PM ET
Speakers:
- CMS Administrator, Chiquita Brooks-LaSure
- CMS Leadership team
Who should attend: National and local stakeholders and partners
To Join the Call Click Here: https://cms.zoomgov.com/j/
Questions: We want to hear from you. Questions can be submitted in advance of the webinar by emailing Partnership@cms.hhs.gov
HHS: Availability of Add’l $25.5 Billion in COVID-19 Provider Funding
HHS Announces the Availability of $25.5 Billion in COVID-19 Provider Funding
This morning the Department of Health and Human Services (HHS) announced that it will be making $25.5 billion in new funding available for healthcare providers affected by the COVID-19 pandemic. The funding, available through the Health Resources and Services Administration (HRSA) will include $8.5 billion in American Rescue Plan Act (ARPA) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic.
Getting additional financial relief for ground ambulance service providers who are still struggling from the lost revenue and increased expenditures resulting from being on the frontlines of responding to the pandemic has been a top priority for the AAA. The AAA along with the International Association of Fire Chiefs, International Association of Firefighters, National Associations of EMTs and National Volunteer Fire Association have continually pressed HHS to release the remaining funds. We strongly encourage all AAA members to submit an application regardless of whether you have applied for previous rounds of funding.
Consistent with the requirements included in the Coronavirus Response and Relief Supplemental Appropriations Act of 2020, PRF Phase 4 payments will be based on providers’ lost revenues and expenditures between July 1, 2020, and March 31, 2021 (Q3 – Q4 2020 and Q1 2021). The PRF Phase 4 will reimburse smaller providers, who tend to operate on thin margins and often serve vulnerable or isolated communities, for their lost revenues and COVID-19 expenses at a higher rate compared to larger providers. PRF Phase 4 will also include bonus payments for providers who serve Medicaid, CHIP, and/or Medicare patients, who tend to be lower- income and have greater and more complex medical needs. HRSA will price these bonus payments at the generally higher Medicare rates to ensure equity for those serving low-income children, pregnant women, people with disabilities, and seniors.
Consistent with the focus of the ARPA, HRSA will make ARPA rural payments to providers based on the amount of Medicaid, CHIP, and/or Medicare services they provide to patients who live in rural areas as defined by the HHS Federal Office of Rural Health Policy. As rural providers serve a disproportionate number of Medicaid and CHIP patients who often have disproportionately greater and more complex medical needs, many rural communities have been hit particularly hard by the pandemic. Accordingly, ARP rural payments will also generally be based on Medicare reimbursement rates.
In the announcement, HHS stated that it would “expedite and streamline” the application process and minimize administrative burdens, providers will apply for both programs in a single application. HRSA will use existing Medicaid, CHIP and Medicare claims data in calculating payments. The application portal will open on September 29, 2021. HHS has stated that to ensure that these provider relief funds are used for patient care, PRF recipients will be required to notify the HHS Secretary of any merger with, or acquisition of, another health care provider during the period in which they can use the payments. They have stated that providers who report a merger or acquisition may be more likely to be audited to confirm their funds were used for coronavirus-related costs.
To promote transparency in the PRF program, HHS also released detailed information about the methodology utilized to calculate PRF Phase 3 payments. Providers who believe their PRF Phase 3 payment was not calculated correctly according to this methodology will now have an opportunity to request a reconsideration. HHS announced that additional details on the PRF Phase 3 reconsideration process will be released at a later date.
In addition, many of you attended the PRF Reporting Q&A AAA webinar yesterday with Asbel Montes, Brian Werfel, and Scott Moore. HHS has acknowledged the challenges facing many providers across the country due to recent natural disasters and the Delta variant, HHS announced a final 60-day grace period to help providers come into compliance with their PRF Reporting requirements if they fail to meet the deadline on September 30, 2021. While the deadlines to use funds and the Reporting Time Period will not change, HHS will not initiate collection activities or similar enforcement actions for non-compliant providers during this grace period.
Members can access more information about eligibility requirements, the documents and information providers will need to complete their application, and the application process for PRF Phase 4 and ARP Rural payments by visiting the HRSA website.
The combined application for American Rescue Plan rural funding and Provider Relief Fund Phase 4 will open on September 29, 2021. Like we have done with the previous rounds of HHS funding, we encourage all ambulance service providers to submit an application for this Phase 4 funding. If you have questions regarding this or any COVID-19 related questions, please contact hello@ambulance.org.
Biden Issues Exec Orders Requiring COVID-19 Vaccinations
The Biden Administration Issues Several Executive Orders Requiring Mandatory COVID-19 Vaccination
On September 9, 2021, the Biden Administration issued several Executive Orders which impact more than 100 million workers in an effort to end the COVID-19 pandemic. The two Executive Orders, Executive Order on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees and Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors were highlighted during a Presidential press conference.
During his announcement, President Biden said that there are more than 80 million Americans, who are not vaccinated. As a result he stated that “it is essential that Federal employees take all available steps to protect themselves and avoid spreading COVID-19 to their co-workers and members of the public.” Additionally, the President stated he issued these orders “to promote the health and safety of the Federal workforce and the efficiency of the civil service, it is necessary to require COVID-19 vaccination for all Federal employees, subject to such exceptions as required by law.”
The orders will require that all Federal employees and employees of Federal Contractors mandate vaccination. The President stated that if businesses and individuals want to work with the federal government, they must be vaccinated. Under the order, The Safer Federal Workforce Task Force (Task Force), will issue guidance to all covered agencies consistent with these Orders within seven (7) days.
The President also announced that the U.S. Department of Labor (U.S. DOL) will be issuing emergency rules that will require employers of 100 or more employees to require vaccination or mandatory weekly COVID-19 testing for all workers. Additionally, the President announced that he is expanding requirements for employers to provide paid leave to employees so that they can obtain the COVID-19 vaccinations. He provided no details on how much the paid leave requirement will be expanded.
Lastly, the Centers for Medicare and Medicaid Services (CMS) announced that it will be expanding the vaccination requirements for healthcare facilities that bill Medicare. Currently, the Biden Administration requires that all long-term care staff working for facilities that bill Medicare must be vaccinated against COVID-19. In the latest announcement, CMS stated that it will be expanding the mandatory vaccination requirements to other Medicare-certified facilities, including hospitals, dialysis facilities, ambulatory surgical settings, and home health agencies, and others, as a condition for participating in the Medicare and Medicaid programs. CMS is developing an Interim Final Rule with Comment Period that will be issued sometime in October.
The President’s expanded COVID-19 plan follows numerous states, such as Connecticut, Rhode Island, California, Massachusetts, and several others that have already enacted mandatory vaccination requirements for healthcare, county or municipal, and long-term care workers. Many of states that have enacted mandatory vaccination requirements provided for no vaccination exceptions, or made provisions for medical exceptions to the vaccination requirements.
We will not know the specific vaccine mandate requirements under these new rules until the Task Force, the U.S. DOL, and CMS publishes these emergency rules. It is important for employers to understand that they are still required to engage any employee seeking an accommodation from the mandatory vaccination requirements in the interactive process as required under the Americans with Disabilities Act (ADA) or Title VII of the Civil Rights Act. We recommend employers follow a consistent documented process and seek legal advice when handling any accommodation requests.
We will continue to monitor developments with these new requirements. Be sure to contact the AAA if you have questions about these Executive Orders or need assistance in ensuring you are in compliance.
HHS/ASPR Project ECHO COVID-19 Clinical Rounds
From HHS/ASPR – Project ECHO COVID Clinical Rounds
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Interstate Commission for EMS Personnel Practice Selects Ray Mollers as its Executive Director
National Partner Release, September 1, 2021
From the Interstate Commission for EMS Personnel Practice
For Additional Information, Contact: Dan Manz, Educator, dmanz@emscompact.gov
Interstate Commission for EMS Personnel Practice selects Ray Mollers as its Executive Director
The Interstate Commission for EMS Personnel Practice (ICEMSPP) is pleased to announce the appointment of Mr. Ray Mollers as its first Executive Director. Mr. Mollers will be Commission’s principal administrator and responsible for the day-to-day management of the EMS Compact while leading growth, strengthening operations, and increasing collaboration with state and federal EMS officials, partner organizations, and stakeholders.
Ray joins the EMS Compact team after serving as the Director of Stakeholder Partnerships with the National Registry of Emergency Medical Technicians (NREMT). During his time at the National Registry, he managed stakeholder relationships and led the creation of a team responsible for enhancing partnerships, improving collaboration amongst EMS professionals, and increasing communication with stakeholders and State EMS Offices. Prior to the National Registry, he served our nation with 32 years of combined Federal service with the US Army Special Forces and Department of Homeland Security’s Office of Health Affairs.
“Today, over 300,000 EMS personnel in the United States have a multi-state privilege to practice”, said Joseph Schmider, Chairperson of the ICEMSPP Executive Committee. “With over 20 participating states, it was evident that the EMS Compact needed a full time Executive Director. Ray is an accomplished, humble professional. He was involved with the initial conceptual discussions of an EMS Compact a decade ago and has remained a key advocate since. Ray understands the EMS Compact – its purpose and history – and has established relationships with State EMS Offices and other key national partners.”
“I am so honored and excited to carry forward all the hard work done to date and shepherd the EMS Compact into its next chapter,” says Mr. Mollers.
Ray will start his service as the EMS Compact’s Executive Director on September 20, 2021. Dan Manz, the EMS Compact’s Educator is retiring, but will continue working in that position through the end of 2021 to assure a smooth transition.
For more information visit EMSCompact.gov.
CMS Announces Timeline for National Expansion of Prior Authorization for Repetitive, Scheduled Non-Emergency Ambulance Transportation
On August 26, 2021, the Centers for Medicare and Medicaid Services (CMS) announced its proposed timeline for the national expansion of the Prior Authorization Model for Repetitive, Scheduled Non-Emergent Ambulance Transports (RSNAT). The formal notice appeared in the Federal Register on August 27, 2021.
Background
In December 2014, the Centers for Medicare and Medicaid Services (CMS) implemented a prior authorization model for payment of repetitive, scheduled non-emergent ambulance transportation. Under this Model, ambulance suppliers are required to seek and obtain prior authorization for the transportation of repetitive patients beyond the third round-trip in a 30-day period. Absent prior authorization, the Medicare Administrative Contractors (MACs) are required to subject further claims to prepayment review.
The Model was initially implemented in three states: New Jersey, Pennsylvania, and South Carolina. These “Year 1” states were selected based on relatively high per-capita expenditures on RSNAT. The Model was subsequently expanded in January 2016 to five additional states (Delaware, Maryland, North Carolina, Virginia, and West Virginia) and to District of Columbia. These “Year 2” states were selected based on their inclusion in the same MAC Jurisdiction as one or more of the Year 1 states.
The purpose of the RSNAT Model was to test whether prior authorization would be effective in reducing Medicare expenditures on RSNAT, without adversely impacting beneficiary access to medically necessary services. CMS engaged Mathematica, a public health care research firm, to study the impact of prior authorization on ambulance utilization in the demonstration states. Mathematica issued several reports that concluded that the Model was effective in reducing Medicare expenditures without any measurable impact on the quality of care available to Medicare beneficiaries.
On November 23, 2020, CMS published a notice in the Federal Register indicating that it intended to expand the Prior Authorization Model to all remaining states and U.S. territories. However, citing the current Public Health Emergency, CMS elected not to set a timeline for that national expansion.
The current notice announces that timeline for national expansion
Expansion Timeline
CMS has indicated that the RSNAT Model will be expanded into new states on the following timeline:
| Expansion Date | Affected States |
| December 1, 2021 | Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, and Texas |
| Not earlier than
February 1, 2022 |
Alabama, California, Georgia, Hawaii, Nevada, Tennessee, American Samoa, Guam, and the Northern Mariana Islands |
| Not earlier than
April 1, 2022 |
Florida, Illinois, Iowa, Kansas, Minnesota, Missouri, Nebraska, Wisconsin, Puerto Rico, and the U.S. Virgin Islands |
| Not earlier than
June 1, 2022 |
Connecticut, Indiana, Maine, Massachusetts, Michigan, New Hampshire, New York, Rhode Island, and Vermont |
| Not earlier than
August 1, 2022 |
Alaska, Arizona, Idaho, Kentucky, Montana, North Dakota, Ohio, Oregon, South Dakota, Utah, Washington, and Wyoming |
An analysis of the proposed timeline suggests that CMS has elected to expand the RSNAT Model based on existing Medicare Administrative Contractor (MAC) Jurisdictions. For example, each of the states slated to be included in the December 1, 2021 expansion fall within MAC Jurisdiction H. This MAC Jurisdiction is administered by Novitas Solutions, Inc. Novitas also administers MAC Jurisdiction L, which has been operating under the RSNAT Model since 2014. Thus, CMS likely selected MAC Jurisdiction H for the first stage of the national expansion due to Novitas’ experience in administering the RSNAT Model.
The second stage of the national expansion will occur no earlier than February 1, 2022. This stage will include all states and territories located in MAC Jurisdiction J and MAC Jurisdiction E. MAC Jurisdiction J is administered by Palmetto GBA, LLC, which has been administering the RSNAT Model in MAC Jurisdiction M since 2014. MAC Jurisdiction E is administered by Noridian Healthcare Solutions, LLC. This will be Noridian’s first experience with the RSNAT Model.
The third stage of the national expansion will occur no earlier than April 1, 2022. This stage will include all states and territories located in MAC Jurisdiction 5 (Wisconsin Physicians Service Government Health Administrators), MAC Jurisdiction 6 (National Government Services, Inc.), and MAC Jurisdiction N (First Coast Service Options, Inc.)
The fourth stage of the national expansion will occur no earlier than June 1, 2022. This stage will include all states and territories located in MAC Jurisdiction 8 (Wisconsin Physicians Service Government Health Administrators) and MAC Jurisdiction K (National Government Services, Inc.).
The final stage of the will occur no earlier than August 1, 2022. This stage will include all states and territories located in MAC Jurisdiction 15 (CGS Administrators, LLC) and MAC Jurisdiction F (Noridian Healthcare Solutions, LLC).
Outreach and Education
With the formal announcement of CMS’ timeline for the national expansion of the RSNAT Model, the American Ambulance Association will be increasing its educational efforts related to prior authorization. This will include webinars and other educational materials on the technical elements of the prior authorization process, the importance of third-party documentation, as well as basic best practices related to the transportation of repetitive patients. We encourage all members that may be impacted by the expansion of prior authorization to take advantage of these educational materials.
CMS Releases Medicare COVID-19 Vaccine Data Analysis and PUF
From CMS on August 25, 2021
Today, the Centers for Medicare & Medicaid Services (CMS) released two new resources with information on Medicare beneficiaries on whose behalf at least one fee-for-service (FFS) claim for the administration of the COVID-19 vaccine has been submitted to the Medicare program.
First, we released a paper titled Assessing the Completeness of Medicare Claims Data for Measuring COVID-19 Vaccine Administration. This paper presents preliminary findings on the count of individuals ages 65 and older with at least one COVID-19 vaccine administration claim in the Medicare data compared to the count of people 65+ with at least one COVID-19 vaccine dose in the data reported by the Centers for Disease Control and Prevention (CDC). Using data as of June 4th, 2021, we estimate that CMS received a claim for COVID-19 vaccine administration for roughly half of Medicare beneficiaries who have received at least one COVID-19 vaccine dose as compared to the estimated counts based on adjusted CDC figures (17.5 million out of 36.6 million). As a result, we recommend that the public apply significant caution when analyzing COVID-19 vaccine administration trends using Medicare claims data.
Second, we released the Medicare COVID-19 Vaccine Public Use File (PUF) which presents a high-level and preliminary overview of Medicare utilization and spending information from Medicare FFS claims for the administration of the COVID-19 vaccine. The PUF shows that between December 11, 2020 and June 30, 2021, Medicare payments for administration of the COVID-19 vaccine were over $1.1 billion. The PUF is based on Medicare FFS claims CMS received by August 6, 2021.
[Note: The Medicare FFS program is paying for COVID-19 vaccine administration on behalf of MA beneficiaries as well as for FFS beneficiaries receiving COVID-19 vaccinations in 2020 and 2021.]
EMS Provider Comments Needed on the “Surprise Billing” Interim Final Rule
The Department of Health and Human Services, Department of Labor, and the U.S. Treasury Department (Departments) have issued an Interim Final Rule (IFR) on “surprise billing” that will take effect September 13, 2021. However, the Departments are taking comments on the IFR. While the Congress expressly excluded ground ambulance organizations from the statute that the IFR seeks to implement, the Departments have included a prohibition on balance billing for nonemergency ground ambulance transports that occur after a patient has been stabilized in a facility.
The Congress established an Advisory Committee to consider the best way to address balance billing in the context of ground ambulance services, and the Departments should wait to be advised by that group before subjecting nonemergency ground ambulance transports to the broader balancing billing prohibition.
It is important that the Departments hear from as many stakeholders as possible opposing this expansion of the law. To help you develop a comment letter, we provided the following template that we ask you to tailor to your experience and organization. Tailored letters will be of greater value to the Department as they consider the rules. At a minimum, please customize the templated language to insert information about who you are and where you operate.
The must be submitted by September 7, 2021.
CMS Open Door Forum | Medicare Ground Ambulance Data Collection System
August 12, 2021 Ambulance Open Door Forum
August 12, 2021 | 14:00–15:30 ET
Slide presentation on the Overview of the Medicare Ground Ambulance Data Collection System (PDF) is now available.
The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, August 12, 2021
Start Time: 2:00pm-3:30pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham
Agenda
**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
- Emergency Triage, Treat, and Transport (ET3) Model Update
- ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
- ET3Model@cms.hhs.gov for inquiries
- ET3 Model Listserv for Model updates: https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12521
- ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
Overview of the Medicare Ground Ambulance Data Collection
System
A copy of the presentation will be available on the
Ambulances Services Center website under
Spotlights: https://www.cms.gov/Center/ProviderType/Ambulances-Services-Center
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:
August 12, 2021 | 14:00–15:30 ET | Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
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
1-866-470-7051; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
866-470-7051 and entering the Conference Passcode beginning 1 hours after the
call has ended. The recording is available until August 14, 2021, 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. Please allow up to three weeks to get both the
audio and transcript posted to: https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.