CMS Announces 2020 Ambulance Inflation Factor

On October 4, 2019, CMS issued Transmittal 4407 (Change Request 11497), which announced the Medicare Ambulance Inflation Factor (AIF) for calendar year 2020. 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…

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CMS Announces Comment Period for National Expansion of Prior Authorization Process

On October 29, 2019, the Centers for Medicare and Medicaid Services (CMS) posted a notice in the Federal Register announcing an opportunity for the public to provide comments on the proposed national expansion of the prior authorization process for repetitive, scheduled non-emergent ground ambulance transportation.  CMS refers to this process as its “RSNAT Prior Authorization…

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HHS OIG Issues Proposed AKS Safe Harbor Rule

On Thursday, October 17, 2019, the HHS Office of the Inspector General (OIG) issued a proposed rule titled “Medicare and State Health Care Programs: Fraud and Abuse; Revisions to Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalties Regarding Beneficiary Inducements.”  The proposed rule would amend the existing safe harbors to the Federal Anti-Kickback…

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Submit Comments on Ambulance Data Collection System

Yesterday, the AAA submitted our comment letter to the proposed rule on changes for FY2020 to the Medicare ambulance fee schedule. The comment letter focused on the section of the proposed rule on the ambulance data collection system. For a copy of the detailed 28-page comment letter, please click here.

Read the AAA Comment Letter

The AAA is very pleased with the approach CMS is taking on data collection which is consistent with the intent of the Congress and the methodology developed and advocated by the AAA. While the AAA comment letter is extremely detailed, our only concern is CMS was not able to test or pilot the sampling methodology and data collection instrument prior to inclusion in the proposed rule. Testing would have allowed CMS to fine-tune the survey and may impact the quality of the first year of data.

Now, it is important that AAA members submit their own letters to demonstrate support for the AAA letter and its key points.

AAA members should go to www.regulations.gov and make three points as follows:

  • Our organization supports the approach CMS is proposing to collect ambulance data and we thank CMS and its contractors.
  • Since CMS was unable to test the sampling methodology and data collection tool, we are concerned about the potential quality of the first year of data. We therefore ask CMS to begin education of ambulance service suppliers and providers and work with the American Ambulance Association to adjust the methodology and tool, if necessary, for future data collections.
  • We fully support the specific comments submitted by the American Ambulance Association as to recommended improvements to the data collection tool.

All you need to do is click on www.regulations.gov and include the above three points. Add your first and last name and click “continue” to then finalize your submission.

The AAA has also developed a sample comment letter you can access by clicking here. Go to www.regulations.gov and instead of adding the three points in the comment back, upload your letter.  Please draft your own customized letter using the letter provided by the AAA as a guideline.

Sample Comment Letter

Comments are due by 5:00 pm on Friday, September 27, so please submit your comment letter today! Please also feel free to forward this email to state ambulance associations and other ambulance service organizations.

The AAA will be submitting a second letter in the next week just on seeking clarification around changes to PCS requirements in the proposed rule but will not be asking members to submit similar comments.

We greatly appreciate the work of CMS and its contractors in developing the ambulance data collection system.

Thank you in advance to all of you who take the time to submit comment letters.

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

CMS Announces Extension of Prior Authorization Program

On September 16, 2019, CMS published a notice in the Federal Register that it would be extending the prior authorization demonstration project for another year. The extension is limited to those states where prior authorization was in effect for calendar year 2019. The affected states are Delaware, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina,…

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Preliminary Calculation of 2020 Ambulance Inflation Update

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…

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New SNF Consolidated Billing Edits: FAQs

On April 1, 2019, CMS implemented a new series of Common Working File (CWF) edits that it stated would better identify ground ambulance transports that were furnished in connection with an outpatient hospital service that would be bundled to the skilled nursing facility (SNF) under the SNF Consolidated Billing regime. Unfortunately, the implementation of these…

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CMS Releases Proposed Cost Collection Rule

Today, CMS has released the proposed rule that would establish the ambulance fee schedule cost collection system as required by statute. The AAA is currently reviewing the rule and will provide a more detailed summary in the coming days.

On Tueusday, July 30 at 12:00pm Eastern, the AAA will be hosting a free webinar during which AAA counsel will provide an overview of the proposals in the rule. Do not miss out on this chance for the most up to date information.

Read the Proposed Rule

Sign Up for the Webinar

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

House Energy & Commerce Subcommittee Takes Action on Balance Billing

On July 11, 2019, the House Energy and Commerce Committee Health Subcommittee held a markup in which they advanced 10 health care bills, including legislation on surprise/balance billing. This legislation, H.R. 3630, the No Surprises Act attempts to address out-of-network surprise medical bills. The AAA Government Affairs team has been in regular communication with the…

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2019 Ambulance Ride-Along Toolkit

AAA ambulance emt member legislation

2019 Ride-Along Toolkit Now Available!

Educating your members of Congress about ambulance industry issues makes them much more likely to support your efforts. An easy and effective way to educate them is to invite them to participate in a local Ambulance Ride-Along!

Congress is scheduled to adjourn on July 27 for their August congressional recess with members of Congress returning home to their districts and states. This is the perfect opportunity for you to educate your members of Congress about those issues, in particular the Public Safety Officers Benefit (PSOB), permanent ambulance relief and ambulance cost data collection which are important to your operation. The most effective way to deliver these key messages is to host your member of Congress or their staff on a tour of your operation and an ambulance ride-along. The AAA has made the process of arranging a ride-long or scheduling a meeting easy for you with our 2019 Congressional Ride-Along Toolkit.

Are you willing to host a Member of Congress at your service but unsure of how to set it up? Email or call Aidan Camas at acamas@ambulance.org – (202) 802-9026 and Aidan can help you set up a meeting.

Everything you need to arrange the ride-along or schedule a meeting is included in the Toolkit. Act now and invite your elected officials to join you on an Ambulance Ride-Along!

Update on AAA Legislative Priorities

The American Ambulance Association has been working hard to accomplish the legislative goals of the membership in the 116th Congress. The AAA would like to take this opportunity to provide an update on what we have accomplished thus far in the 116th Congress.

Balance/Surprise Billing

Balance/surprise billing is a hot button issue that recently came into the spotlight at the start of the 116th Congress. With the President’s announcement calling for Congress to pass legislation that would end surprise billing for patients, there has been an increase in Congressional action on the issue including introduced legislation, discussion drafts and hearings in all committees of jurisdiction. The AAA has been working tirelessly with the Congressional committees of jurisdiction to educate Members and staff on the unique characteristics of EMS systems and that it would be inappropriate to apply the same restrictions on balanced billing to ground ambulance services.

The AAA has formed a working group comprised of AAA member volunteers that have worked on policy and messaging on balance billing. The working group has submitted comments to the Energy and Commerce Committee and Senate HELP committees advocating that the ambulance industry is unique from other stakeholders, and as such, should be looked at differently. Ambulance service providers and suppliers are required by law to treat and transport all patients, regardless of their ability to pay and are heavily regulated at the local level. The AAA has been working to communicate these factors that place the ambulance industry in a different situation than many other stakeholders.

Public Safety Officers Death Benefit (PSOB)

The Public Safety Officers Death Benefit (PSOB), a one-time benefit paid to families of first responders killed in the line of duty, is an issue that the AAA has passionately advocated for over many years. In the 116th Congress, the AAA has secured introduction of legislation in the House of Representatives, H.R. 2887, the Emergency Medical Service Providers Protection Act. H.R. 2887 would extend the PSOB to first responders employed by private for-profit EMS agencies. The AAA was able to secure several commitments from Members of Congress to cosponsor the legislation during Stars of Life meetings in Washington, DC. In addition to taking action to move H.R. 2887 through the legislative process, the AAA will be engaging in an outreach campaign in the next few weeks.

Dialysis Off-Set Restructuring

The AAA has worked toward reintroduction of legislation to restructure the offset that was passed into law in the Bipartisan Budget Act of 2018 (H.R. 1892) in the 115th Congress. This offset included a total cut of 23% to the Medicare reimbursement for basic life support (BLS) non-emergency transports performed by all ambulance service suppliers and providers to and from dialysis centers. This cut served as an offset to the 5-year extension of Medicare add on payments that our industry worked hard to get extended.

The AAA has secured introduction of legislation in both the House and Senate. H.R. 3021 was introduced by Representatives LaHood (R-IL) and Sewell (D-AL) and S. 228 by Senators Cassidy (R-LA) and Jones (D-AL). If passed, this legislation would change the cut that is currently in place so that it applies specifically to companies conducting over 50% ESRD non-emergency transports. Those ambulance services with over 50% ESRD transports would get a cut of 29.5%, while those doing less would receive a 15.5% cut. The AAA will continue to work toward movement and passage of this legislation that would better distribute the reduction to those providers which do almost exclusively non-emergency dialysis transports and thus have a lower cost of providing services.

Medicare Priorities Bill

The AAA has crafted legislation that is specifically aimed at addressing major Medicare ambulance industry issues. The issues that will be included in future legislation include making Medicare ambulance add-ons permanent, implementing a prior-authorization program across the nation, allowing for transportation to alternative destinations, reducing regulatory burdens, and providing relief through maintaining many zip codes as rural following the next census. The AAA is working to get this Medicare priorities legislation introduced in the coming months so that we can get to work on solving these Medicare issues that impact our industry as a whole.

VA Legislation

Another priority that that the AAA has been diligently working toward getting introduced is Veterans Affairs (VA) legislation. The Veterans Reimbursement for Emergency Ambulance Services Act (VREASA) introduced by Congressman Tipton (R-CO) would provide veterans with reimbursement for emergency ambulance services when a Prudent Layperson would have a reasonable expectation that a delay in seeking immediate medical attention will jeopardize the life or health of the veteran. This legislation was introduced as a result of the VA consistently requiring all medical records be provided, including the records of treatment after the emergency service has taken place. Should those records show that it was not a life threatening emergency or a false alarm, the claim for reimbursement is being denied. The VA legislation would mandate that the VA apply the “prudent layperson” definition of emergency to determine coverage of ambulance claims.

The AAA is also working toward addressing two other issues with the VA to enforce more prompt payment by the VA and treating the VA as the first payor, similar to Medicare, as it is determined whether there is a different primary payor. The AAA has been working with Senators Collins and Tester on language help solve this ongoing and serious reimbursement issue.

In our next update, we will be reporting on the progress the AAA has made this year on regulatory issues.

Questions? Contact Us

If you have questions about the discussion draft or balance billing initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support

CMMI Releases Preview of ET3 RFA

On May 22, 2019, the Center for Medicare and Medicaid Innovation (CMMI) released a preview of the Request for Applications (RFAs). This documentation will be used by ambulance providers and suppliers to apply for inclusion as “Participants” in the Emergency Triage, Treat, and Transport (ET3) pilot program. Webinar: Learn More About the RFA June 13,…

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House Introduces PSOB Bill (H.R. 2887)

The American Ambulance Association (AAA) is pleased to announce that Congressman Lee Zeldin (R-NY-01) and Congressman Thomas Suozzi (D-NY-03) have introduced H.R. 2887, the “Emergency Medical Services Providers Protection Act.” This piece of legislation would extend the Public Safety Officers’ Benefit (PSOB) to cover first responders who work for private providers. The PSOB Program provides death and education benefits to survivors of fallen law enforcement officers, firefighters, and other first responders, and disability benefits to officers catastrophically injured in the line of duty.

The AAA has advocated tirelessly for years that all first responders killed in the line of duty, should be eligible for this benefit regardless of who their employer is. Many of the nation’s first responders work for more than one EMS Agency. Local communities throughout the country decide which organization is best fit to provide high quality mobile healthcare to their community. For large parts of the country, privately run ambulance services have been providing high quality health care, and responding to the same natural disasters, incidents, etc. as their peers for decades.

It is common for Paramedics and EMTs to also work/volunteer as firefighters and vice versa. Currently, if a line of duty death occurs, whether first responders receive this benefit depends on which uniform they were wearing that day. A firefighter picking up an extra shift with a local ambulance service could end up being ineligible for this benefit if that company happens to be privately run. The AAA believes this legislation acknowledges the vital role that all first responders play in keeping our communities safe and healthy. If passed, this change would apply to injuries sustained on or after March 1, 2007.

The AAA thanks Congressman Zeldin and Suozzi for taking the lead on this critical issue. AAA members are encouraged to contact their representatives about co-sponsoring H.R. 2887. Full text of the Bill is not yet available online but can be read here. Please contact the AAA’s Government Affairs team if you have any questions.

Questions? Contact Us

If you have questions about the discussion draft or balance billing initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

CMS Releases ET3 Request for Applications (RFA)

Just minutes ago, the Centers for Medicare & Medicaid Services (CMS) announced the release of the Request for Applications (RFA) for the Emergency Triage, Treat, and Transport (ET3) Model. The RFA can be found here.

CMS is not accepting applications at this time but has released the RFA so that those ambulance services thinking about submitting an application can review it. In the notice, CMS also shared some FAQs on ET3.

The AAA team is currently reviewing the RFA and will be sending out a notice with additional details shortly.

Member Update on Balance Billing

This morning Ruth Hazdovac and Aidan Camas of AAA staff and Kathy Lester, Esq, Healthcare Consultant to the AAA attended a briefing held by the House Energy & Commerce Committee on the issue of surprise/balance billing. At the briefing, staff for Chairman Frank Pallone (D-NJ) and Ranking Member Greg Walden (R-OR) announced that they would be releasing a bipartisan discussion draft, the No Surprises Act, which would “protect consumers from surprise medical bills and increase transparency in our health care system.”

As of now, ground and air ambulances are NOT included in the discussion draft. However, the committee is asking for comments on ground and air ambulance and recommendations on how to provide relief to the consumer in this area. The AAA has a Balance Billing Work Group that is hard at work developing a policy recommendation that will work for our members.

The House Ways and Means Health Subcommittee Chairman Lloyd Doggett also announced today that the Health Subcommittee will hold a hearing next week entitled “Hearing on Protecting Patients from Surprise Medical Bills.” AAA Staff will be at the briefing and provide a timely update to membership on any developments.

The AAA team will be submitting comments and policy recommendations based off the work of the Balance Billing Work Group to both the Energy & Commerce and Ways & Means Committee to ensure that the views of our members are well represented. We will also be reaching out to AAA members in the states of key policymakers on the Committees to submit comments, as well. The AAA will also provide members with key talking points in the event they are contact by their Members of Congress or their staff.

Questions? Contact Us

If you have questions about the discussion draft or balance billing initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

HHS OIG Issues Advisory Opinion on Community Paramedicine

HHS OIG Issues Advisory Opinion Permitting Community Paramedicine Program Designed to Limit Hospital Readmissions On March 6, 2019, the HHS Office of the Inspector General (OIG) posted OIG Advisory Opinion 19-03. The opinion related to free, in-home follow-up care offered by a hospital to eligible patients for the purpose of reducing hospital admissions or readmissions….

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Update on New SNF Edits

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing. In a Member Advisory issued last week, the AAA provided an update on a series of new Common Working File (CWF) edits intended to identify…

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CMS SNF Edits Go Into Effect – April 1, 2019

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing On November 2, 2018, the Centers for Medicare and Medicaid Services (CMS) issued Transmittal 2176 (Change Request 10955), which would establish a new series of…

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Release: CMMI Announces Ambulance Innovative Payment Pilot Program

February 14, 2019

For Immediate Release
Contact Maria Bianchi
American Ambulance Association
202-802-9020
info@ambulance.org

CMMI Announces Ambulance Innovative Payment Pilot Program

Washington, DC – Today, the Centers for Medicare & Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) announced the launch of the Emergency Triage, Treat and Transport (ET3) Model.  During the next five years, this model will test paying ambulance providers and suppliers when they transport beneficiaries to locations other than an emergency department, if the alternative location is more appropriate medically for the patient.  It will also test paying for health care services provided by qualified health care professionals or through telehealth at the scene even if the ambulance does not transport the patient.

While there are several important details yet to be released, this model appears to track the recommendations the American Ambulance Association, our members, and other industry partners have been working with CMS to implement.

“Over the last 7 years, the AAA and our members have been working to develop an innovative payment framework to modernize the Medicare ambulance benefit,” said AAA President Aarron Reinert. “We are pleased that CMS is taking this important step and look forward to working closely with Administrator Verma, Director Boehler and their teams on the details of the ideas announced today to ensure the appropriate implementation.”

Representatives of the American Ambulance Association also participated in the CMS announcement of this model today in DC.  Senior Department of Health and Human Services (HHS) officials including Secretary Alex Azar, CMS Administrator Seema Verma and CMMI Director Adam Boehler spoke at the event. AAA President-Elect Shawn Baird represented the AAA at the announcement.

While the details of the program are still under development and will be communicated through program guidance, a few general details were provided at the event.

The Emergency Triage, Treat and Transport (ET3) Model, would test two new ambulance payment methods. Under ET3, participating ambulance service providers or suppliers would be able to receive payment for:

  • treatment in place with a qualified health care practitioner, either on-the-scene or connected using telehealth; and
  • for unscheduled, emergency transport of Medicare beneficiaries to alternative destinations (such as 24-hour care clinics) other than destinations covered under current regulations (such as hospital EDs).

The program will be national in scope and thus open to all ambulance service suppliers and providers who meet the program requirements, which are still being finalized. The program will be voluntary so providers and suppliers who chose not to participate can continue to be paid under current policy. CMS anticipates releasing applications for the program this summer and an anticipated start date for the program in early 2020.

While seeing the specific details of the program will be crucial, we are very pleased that CMMI is announcing its commitment today to test multiple innovative payment models for ambulance service providers and suppliers. The AAA and our volunteer leaders and members have been working in a collaborative manner with other EMS organizations for the last 5 years to develop an evidence-based, data-driven structural framework to support the adoption of innovative payment models for ambulance emergency and non-emergency services. In 2016, the AAA issued a joint statement with NAEMSP, NAEMSO, and NAEMT outlining this framework. During the last two year, the AAA has worked closely with the Congress, CMS and the CMMI to seek the implementation of this framework. To encourage as broad an adoption as possible, we have focused on achieving these goals through the regulatory process.

The AAA is committed to the development and implementation of innovative payment models.  It is critical that they be designed in a manner that will ensure their success. Adoption of the framework along with having the necessary data to establish reimbursement rates that reflect the cost of providing ambulance services will usher in a new era of ambulance services for not only Medicare beneficiaries, but also for all Americans. As part of the effort to modernize the ambulance benefit, ambulance service suppliers should be recognized as providers of health care services and not merely a transportation benefit. The days of merely driving patients to and from other providers are long gone.

We believe that our efforts and those of the Administration will help us achieve this exciting goal. The AAA supports expanding the destination site for 9-1-1 and similar calls, which is currently limited to hospital emergency departments. For some patients, it is more appropriate to take them to other types of facilities, such as rural health clinics, substance or behavioral health facilities, and inpatient psychiatric hospitals. Allowing ambulance services to use state and local protocols to help triage patients to the most appropriate setting will help address the opioid epidemic and better care for patients with behavioral health issues, as well as urgent low acuity medical conditions.

We want to thank the Congress and the groups at CMS and CMMI who began to lay the ground work for the next phase of innovative payment models last winter as well. We also greatly appreciate the efforts of other EMS representatives who worked with the CMMI to help push for the pilot program.

The AAA will continue to advocate for data and evidence-based changes to the Medicare ambulance fee schedule which allow ambulance service providers and suppliers to provide even better medical services to patients.

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About the American Ambulance Association
The American Ambulance Association, formed in 1979, represents 500 ambulance services across the United States that serve their communities with emergency medical services, interfacility mobile healthcare, and community paramedicine 24/7/365. The Association serves as a voice and clearinghouse for mobile healthcare, and views prehospital care as an essential part of the total public health care system.

HHS OCR Requests Feedback on HIPAA Privacy Rule

On January 28, 2019, the Office of Health and Human Services the Office for Civil Rights (HHS OCR) issues a Request for Information (RFI) seeking input from covered entities regarding several aspects of the Health Insurance Portability and Accountability Act (HIPAA).  Specifically, the HHS OCR is seeking input regarding several elements of the Privacy Rule,…

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