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. 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 (more…)

2019 AAA Election—Floor Nominations

To All AAA Members, In accordance with the AAA Bylaws, floor nominations for the Board, Ethics and Honorary Membership positions for the 2019 election will be accepted by the AAA board prior to their approval of the slate of candidates. If you are interested in a position or nominating another member, but have not filled out your nomination form or candidate’s questionnaire, please contact a AAA Board member so they can place your name on the slate prior to the closing of nominations. All floor nominations must be received by 5:00pm Eastern on Wednesday, September 18, 2019. If you have any questions, please contact Maria Bianchi, AAA Executive Director (mbianchi@ambulance.org). Please follow this link to contact a AAA board member....

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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, Virginia and West Virginia, as well as the District of Columbia. The extension will run through December 1, 2020.  In its notice, CMS indicated that the prior authorization demonstration project is being extended “while we continue to work towards nationwide expansion.”  This strongly suggests that CMS believes the program has met the statutory requirements for nationwide expansion under the Medicare Access and CHIP Reauthorization Act of 2015.  However, CMS indicated that it would use the additional year to continue to test whether prior authorization helps reduce expenditures, while maintaining or improving the quality of care offered to Medicare beneficiaries. CMS has also updated its CMS Ambulance Prior Authorization webpage to reflect the expansion of prior authorization in the existing states through December 1, 2020....

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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 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 2019, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 1.65%. CMS has yet to release its estimate for the MFP in calendar year 2020. However, assuming CMS’ projections for the MFP are similar to last year’s projections, the number is likely to be in the 0.6% range. Accordingly, the AAA is currently projecting...

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CMS Open Door Forum & Member Q&A – August 28

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Wednesday, August 28 at 2:00 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call. CMS Ambulance Open Door Forum August 28 | 2:00 PM ET Participant Dial-In Number:  1-888-455-1397 Conference ID #: 6609831 Questions? Have more questions? The AAA is here to help! Following the ODF the AAA will be publishing a follow up blog post going over any updates and important announcements. AAA Follow Up Q&A August 28 | 3:00 PM ET 1-800-250-2600 Pin: 82802314# Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Krista Cuthbert; and AAA Payment Reform Committee Chair, Asbel Montes....

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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 new edits has been anything but seamless. Over the past few weeks, I have received numerous phone calls, texts, and emails from AAA members reporting an increase in the number of Medicare claims being denied for SNF Consolidated Billing. This FAQ will try to explain why you may be seeing these denials.  I will also try to provide some practical solutions that can: (1) reduce the number of claims denied by the edits and (2) help you collect from the SNFs, when necessary. Please note that, at the present time, there is no perfect solution to this issue, i.e., there is nothing that you can do to completely eliminate these claim denials.  The solutions discussed herein are intended only to minimize the disruption to your operations caused by these denials.   I am new to Medicare ambulance billing. Can you explain what the SNF Consolidated Billing...

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Nominations Open – AAA Board of Directors!

Call For Nominations Now Open! In accordance with the Bylaws of the American Ambulance Association, it is time to call for members in good standing that wish to serve on the Board of Directors. The AAA is now seeking candidates for the following positions: Region I Director (CT, MA, ME, NH, NJ, NY, RI & VT) Region II Director (AL, DE, DC, FL, GA, MD, MS, NC, PA, SC, VA, WV) Region III Director (IL, IN, KY, MI, OH, TN WI) Region IV Director (AR, IA, KS, LA, MN, MO, OK, ND, NE, SD, TX) Region V Director (AK, AZ, CA, CO, HI, ID, MT, NM, NV, OR, UT, WA, WY Individuals who wish to be considered for an elected position as Regional Director must: 1. Be the designated representative of an Active member of the AAA, in good standing; 2. Be ready to devote time and effort to matters which concern the Board of Directors and to actively participate in all Board activities; 3. Be prepared to assist other AAA members with concerns and problems which relate to the ambulance industry and the workings of the AAA; and, 4. Understand that these positions provide no compensation for time or reimbursement for expenses. All travel-related expenses, including...

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