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, including the following: Encouraging information-sharing for treatment and care coordination Facilitating parental involvement in care Addressing the opioid crisis and serious mental illness Accounting for disclosures of PHI for treatment, payment, and health care operations as required by the HITECH Act Changing the current requirement for certain providers to make a good faith effort to obtain an acknowledgment of receipt of the Notice of Privacy Practices I am aware that several AAA member services who have struggled with many of the HIPAA restrictions regarding the sharing of PHI with other healthcare entities.  In particular, with regard to individuals who suffer opioid overdoses and efforts to ensure the individual has access to drug treatment programs.  Additionally, HHS OCR is seeking input from covered healthcare providers regarding the “good faith” efforts to obtain acknowledgement of the receipt of Privacy Practices.  This has been a considerable challenge for...

This content is available only to AAA members.
Log In or Register

CMS Declines to Extend Temporary Moratorium

On January 30, 2019, the Centers for Medicare & Medicaid Services (CMS) announced that it had elected not to extend its temporary moratoria on the enrollment of new Medicare Part B non-emergency ground ambulance providers and suppliers in the states of New Jersey and Pennsylvania. These enrollment moratoria expired on January 29, 2019.

AAA Releases 2019 Medicare Rate Calculator

AAA 2019 Medicare Rate Calculator Now Available! The American Ambulance Association is pleased to announce the release of its 2019 Medicare Rate Calculator tool. The AAA believes this is a valuable tool that can assist members in budgeting for the coming year. This calculator has been updated to account for recent changes in Medicare policies, including the 2019 Ambulance Inflation Factor (2.3%) and continuation of the current temporary add-ons. To access the Rate Calculator, please CLICK HERE....

This content is available only to AAA members.
Log In or Register

Update on Government Shutdown and Sequestration

As the government shutdown drags on the negative impacts continue to grow. If the shutdown continues through January 24, 2019, which is looking likely at this point, current law will require the Trump Administration to cut about $839 million from non-exempt federal benefit programs to avoid increasing the deficit. This is a result of the “PAYGO” (pay as you go) law which requires spending increases or tax cuts to be offset with cuts to programs or additional revenue to avoid increasing the deficit. As the largest nonexempt benefit program, it is likely that Medicare would experience the worst of these cuts through sequestration. While the Trump Administration has not yet issued a sequestration order, there is a distinct possibility that one could be issued if the shutdown continues much longer. A sequestration order would mean an additional across the board cut to all Medicare providers, including ambulance services. Ambulance service providers are still feeling the impact of the 2% sequestration cut that has been in effect the past few years. Any new cuts would likely start out being targeted at administrative tasks which could slow payments to providers. Temporary cuts would be expensive for the administration to facilitate and is...

This content is available only to AAA members.
Log In or Register

Reports of Ambulance Pilot Programs

Earlier this week, health care trade press reported that the Centers for Medicare and Medicaid Innovation (CMMI) will be rolling out in the coming weeks several innovation pilot programs including a couple related to ambulance services. Over the last several months, the AAA has been meeting with CMMI and CMS officials about a pilot or change in policy to allow for coverage of transports by ambulance to destinations other than emergency departments. These efforts have coincided with efforts by others in the industry on alternative destination as well as reimbursement on some form of treat and refer of a patient. The AAA is pleased that CMMI and CMS have listened to the recommendations of the AAA and other groups in moving forward on testing different policy changes. However, it is critical that the AAA and our members see the specifics of any pilot programs before we determine whether to support the initiative. CMMI cannot provide details of the program until available publicly and all the specifics of such programs are critical to whether they will be a success and if it will be a positive change for the industry and our ability to provide quality patient care. We will provide you details of the pilot programs and the position of (more…)

Update on HHS OIG Reports on Ambulance Services

Update on HHS Office of the Inspector General Reports on Ambulance Services The HHS Office of the Inspector General (OIG) released an update to the Work Plan as the year comes to a close.  There are no new projects specific to ambulance services, but the update does provide a summary of three projects that have been completed or are in progress. Medicare Part B Payments for Ambulance Services Subject to Part A Skilled Nursing Facility Consolidated Billing Requirements (expected release 2019). In this work, the OIG  seeking to determine whether ambulance services paid by Medicare Part B were subject to Part A SNF consolidated billing requirements. The OIG will also assess the effectiveness of edits in CMS’s Common Working File to prevent and detect Part B overpayments for ambulance transportation subject to consolidated billing. Prior OIG reports have identified high error rates and significant overpayments for services subject to SNF consolidated billing. Ambulance Services – Supplier Compliance with Payment Requirements (partially completed; remainder expected release 2019). Prior OIG work has found that Medicare made inappropriate payments for advanced life support emergency transports. The OIG seeks to determine whether Medicare payments for ambulance services were made in accordance with Medicare requirements. ...

This content is available only to AAA members.
Log In or Register

Federal District Court Judge Strikes Down the ACA

On December 14, 2018, a federal district court judge for the Northern District of Texas issued a ruling striking down the Affordable Care Act (ACA) on the grounds that the Individual Mandate was unconstitutional, and that the rest of the law cannot withstand constitutional scrutiny without the Individual Mandate. District Court Judge Reed O’Connor’s decision relates to a lawsuit filed earlier this year by 20 states and two individuals. The plaintiffs argued that the Tax Cuts and Jobs Act of 2017 — which amended the Individual Mandate to eliminate the penalty on individuals that failed to purchase qualifying insurance effect January 1, 2019 — rendered the Individual Mandate unconstitutional. The plaintiffs further argued that the Individual Mandate was inseverable from the rest of the ACA, and, therefore, that the entire ACA should be struck down. The defendants in this case were the United States of America, the U.S. Department of Health and Human Services (HHS), Alex Azar, in his capacity as the Secretary of HHS, and David J. Kautter, in his capacity as the Acting Commissioner of the Internal Revenue Service (IRS). 16 states and the District of Columbia intervened as additional defendants. In order to properly understand the district (more…)

CMS Announces 2019 Ambulance Inflation Factor

On November 30, 2018, CMS issued Transmittal 4172 (Change Request 11031), which announced the Medicare Ambulance Inflation Factor (AIF) for calendar year 2019. 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 2018, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased 2.9%. CMS further indicated that the CY 2019 MFP will be 0.6%. Accordingly, CMS indicated that the Ambulance Inflation Factor for calendar year 2019 will be 2.3%....

This content is available only to AAA members.
Log In or Register