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. ...

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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%....

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CMS Announces Extension of Prior Authorization Program

On November 30, 2018, CMS issued a notice on its website 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 2018. The affected states are Delaware, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina, Virginia and West Virginia, as well as the District of Columbia. The extension will run through December 1, 2019.  CMS indicated that the extension will provide it with an additional year to evaluate the prior authorization program, and to determine whether the program meets the statutory requirements for nationwide expansion under the Medicare Access and CHIP Reauthorization Act of 2015. CMS has also updated its Ambulance Prior Authorization FAQs and its Physician/Practitioner Letter to reflect the expansion of the program. The updated FAQ and Physician Letter can be downloaded from the CMS Ambulance Prior Authorization webpage by clicking here....

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Senate Introduces NEATSA Act Companion Bill (S. 3619)

Earlier this year, Congress included in the Bipartisan Budget Act of 2018 an offset to go along with the extension of the add-ons that will cut reimbursement for BLS nonemergency transports to and from dialysis centers by an additional 13%. This will be on top of the existing 10% reduction. Senators Bill Cassidy (R-LA) and Doug Jones (D-AL) just introduced S. 3619 which would restructure the offset so that a majority of the additional reduction would be focused on those ambulance service agencies in which 50% or more of their volume are repetitive BLS nonemergency transports to and from dialysis centers. S. 3619 will serve as a companion Bill to the House version, the NEATSA Act (H.R.6269) by Congressman LaHood (R-IL) and Congresswoman Sewell (D-AL) which was introduced in June 2018. The additional cut went into effect on October 1 and impacted AAA members and the AAA are working to get this legislation passed. The AAA will be sure to keep members updated as this legislation moves through Congress. 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 (more…)

Rural Health Day Advocacy Update

Happy National Rural Health Day! Thank you to all of the ambulance service providers who work hard providing life-saving treatment in rural areas every day. In part of our ongoing advocacy efforts, the AAA sent a letter today to the Rural Caucuses in the United States Senate and House of Representatives. Addressed to leadership of the caucuses, Sen. Pat Roberts (R-KS), Sen. Heidi Heitkamp (D-ND), Rep. Adrian Smith (R-NE), and Rep. Tim Walz (D-MN), this in-depth letter highlights the critical work that our members do every day around the country and raises important issues affecting the industry. Issues covered in the letter include: Stabilizing the Ambulance Fee Schedule Make the add-ons permanent and build them into the base rate Use new data from the ambulance cost collection program to ensure reimbursement is adequate going forward New data should be used to assess the problems with the current ZIP-code methodology for determining rural and super-rural services Ambulance Fee Schedule Reform Proposed alternative models for rural ambulance services Encouraging Congress to look at alternative destination options for ambulance service providers Recognizing Ambulance Services as Providers of Health Care Moving non-fire-based ambulance services from suppliers to providers under Medicare The letter also highlights...

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Mid-term Election Analysis

As a result of Tuesdays’ elections, Democrats will control the U.S. House of Representatives next Congress and Republicans will have a larger majority in the United States Senate. Presently, Democrats have gained a net of 30 seats in the House with Republicans netting two seats in the Senate. Democrats needed to capture 23 seats from Republicans to gain the majority. There are still several races in the House and Senate to be called which will likely add to those totals. Akin Gump, the lobbying firm for the AAA, has put together a synopsis of the election results as of this morning and a slide deck on historical trends and the outcome of races called so far. Key supporters of the industry who will not be returning next Congress include Representatives Peter Roskam (R-IL), Mike Coffman (R-CO) and Erik Paulsen (R-MN). All three members have been supportive of ambulance initiatives with Roskam in his position as Chair of the House Ways and Means Health Subcommittee and Paulsen as a member of the Subcommittee. Coffman sponsored legislation to apply the prudent layperson definition to emergency ambulance services provided to veterans. In late breaking news, the Senate race in Montana was called in favor for (more…)