President’s Perspective January 2019

Dear Fellow AAA Members, Happy New Year from the American Ambulance Association! We enter this new year ready to rise together as an industry to face the mobile healthcare’s challenges and opportunities. Advocacy Update The AAA worked hard in the 115th Congress to achieve many legislative and regulatory wins for the industry. Thanks to the AAA Board, volunteer leaders, staff and consultants, and members alike, we were able to accomplish many of our goals to improve payment policies and overall regulations that will benefit AAA members and the industry as a whole. Last year, the AAA ensured the inclusion and passage of a 5-year extension of the ambulance Medicare add-on payments through December 31, 2022 as part of the Bipartisan Budget Act of 2018. The AAA also successfully pushed our preferred method for data cost collection using a survey which is the most likely to provide useful data for future payment reform as well as be the least burdensome on ambulance service providers. In coordination with particular AAA members, the AAA worked with Senator Collins to include report language to accompany the FY2019 Senate VA Appropriations bill which directs the VA to use the prudent layperson standard for determining emergency (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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CMS Posts 2019 Public Use File

On November 28, 2018, CMS posted the 2019 Ambulance Fee Schedule Public Use Files. These files contain the amounts that will be allowed by Medicare in calendar year 2019 for the various levels of ambulance service and mileage. These allowables reflect a 2.3% inflation adjustment over the 2018 rates. The 2019 Ambulance Fee Schedule Public Use File can be downloaded from the CMS website by clicking here. Unfortunately, CMS has elected in recent years to release its Public Use Files without state and payment locality headings. As a result, in order to look up the rates in your service area, you would need to know the CMS contract number assigned to your state. This is not something the typical ambulance service would necessarily have on hand. For this reason, the AAA. has created a reformatted version of the CMS Medicare Ambulance Fee Schedule, which includes the state and payment locality headings. Members can access this reformatted fee schedule here....

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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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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 Webinar

Join AAA Government Affairs Committee Chair, Jamie Pafford-Gresham, AAA SVP of Government Affairs, Tristan North, AAA Senior Manager of Federal Affairs, Ruth Hazdovac, and Manager of State & Federal Government Affairs, Aidan Camas, as they provide a brief re-cap of the recent mid-term elections. This pre-recorded webinar provides an update on federal and state election results, and how they may impact our industry. We review possible leadership changes in the House & Senate as well as on key committees of jurisdiction over ambulance related legislation. The webinar also provides a brief look ahead into AAA legislative priorities for 2019. If you have any questions about material covered on the presentation, please email Aidan Camas at acamas@ambulance.org. ►Watch the video on Youtube here...

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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…)