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OIG Announces Modernization of Compliance Program Guidance Documents

Written by Meghan Winesett on . Posted in Executive, Government Affairs, Human Resources, Member-Only.

By Brian S. Werfel, Esq.

On April 25, 2023, the HHS Office of the Inspector General (OIG) posted a notice in the Federal Register that it would be updating its publicly available resources, including its compliance program guidance documents.  The OIG’s Compliance Program Guidances (CPGs) were developed as voluntary, non-binding guidance documents that can assist healthcare providers in developing their own internal controls to ensure adherence to federal laws, regulations, and program requirements.

Specifically, the OIG announced that it will no longer publish updated or new CPGs in the Federal Register.  Instead, updates or new CPGs will now be made available on the OIG’s website.  The OIG will also revise the format for CGS.  The new format will consist of: (1) a General CPG (GCPG) that applies to all healthcare providers and (2) industry-specific CPGs (ICPGs) tailored to the fraud and abuse areas specific to that industry.  The OIG indicated that it anticipates issuing the GCPG by the end of calendar year 2023, with ICPGs being issued starting in calendar year 2024.  The OIG further indicated that it anticipates the first two ICPGs will address Medicare Advantage plans and nursing facilities.

Note: the OIG is not updating its 2003 guidance on compliance programs for ambulance suppliers.  The OIG frequently cites this document in enforcement actions it takes against ambulance providers and suppliers.  Thus, this guidance document remains relevant to this day.  For that reason, A.A.A. members are strongly encouraged to review this document to ensure that their existing compliance program incorporates the elements cited by the OIG.

Previous Compliance Program Guidance for Ambulance Suppliers

In March 2003, the OIG issued its “Compliance Program Guidance for Ambulance Suppliers.”  This document sets forth the basic elements that it believes should be included in any effective compliance program, and then discusses various fraud and abuse and compliance risks associated with the provision of ambulance services under the Medicare Program.

The 7 basic elements identified by the OIG are:

  1. The development of compliance policies and procedures
  2. The designation of a compliance officer or compliance committee
  3. The implementation of education and training programs
  4. The use of internal monitoring and reviews
  5. Policies designed to respond appropriately to detected misconduct
  6. Ensuring open lines of communication
  7. The enforcement of disciplinary standards through well-publicized guidelines

The CPG then goes into greater detail on each of these elements, including specific recommendations on how to properly implement each of these elements.  For instance, the OIG suggests that the organization’s compliance office be a high-level individual who reports directly to the organization’s CEO or Board of Directors.

With respect to the specific fraud and abuse risks associated with ambulance, the OIG highlighted the issue of medical necessity.  The OIG also cited level of service issues (i.e., billing ALS vs. BLS), non-emergency transports, and coordination of benefit issues as particular areas of concern.

 

AAA Provides Comments to the Senate HELP Committee Related to Workforce Shortage

Written by Meghan Winesett on . Posted in Government Affairs, Legislative, Member-Only, News, Recruitment & Retention.

The American Ambulance Association has submitted comments to the Senate Committee on Health, Education, Labor, and Pensions (HELP) in response to their request for input on crafting legislation to address the health care workforce shortage.

Ground ambulance service organizations are facing a severe shortage of paramedics and EMTs which is placing a significant strain on an emergency medical system already in financial distress. We greatly appreciate the opportunity to provide our legislative solutions to the committee to help address the ongoing workforce crisis.

Please see the document linked below, which was sent to the HELP Committee Chairman, Senator Bernie Sanders, and the Ranking Member, Senator Bill Cassidy.

3-17-2023 HELP Workforce Comments

 

Savvik |Ford Vehicles – 3 Day Order Window

Written by AAA Staff on . Posted in AAA HQ, Member-Only, Operations.

The Ford order bank for Super Duty (F250-F600) will open for government orders on 11/7/2022 and will close on 11/10/2022.
This will be the only opportunity to order Super Duty for the entire 2023 model year using a Government Price Concession.
Our vendor understands that it will be challenging for some government customers to project there needs for the entire year, but unfortunately these are the parameters that Ford has set out for them.
Members that are interested in making a purchase during this window will have 30 days to send a purchase order after placing the order. If no PO is received then Ford will automatically cancel the order.
If the Savvik member happens to have a non-government Fleet Id Number (FIN), they can begin ordering 10/20/2022 and will have the ability to order up to 5 units per quarter.

Save on MME! Savvik Vendor Spotlight

Written by AAA Staff on . Posted in Member-Only, Operations, Patient Care.

Who is MME?

 

Master Medical Equipment specializes in sales and service of defibrillators, ventilators, infusion pumps and accessories for EMS and fire. They have the vision to be the industry leader in recertified medical equipment; to earn their customers through quality, value, service, and respect. 
The Industry’s Best:
That’s the MME Promise.
The MME Promise ensures you get quality medical devices with the guarantee of lower prices and fewer headaches. It means you don’t have to sacrifice your entire budget to secure quality equipment. It means you don’t need to worry about the reliability and functionality of their products. It means you can bypass the hustle and cost from other companies and what it ultimately means is a better experience, which leads to a happier you.

MME thoroughly tests each unit to ensure it meets the MME Five-Point Inspection Guarantee, passes all manufacturer guidelines, and satisfies FDA safety certifications before they ship to you. This is the MME Seal of Approval, and all equipment is backed by the MME name and reputation.

Having been in the business for over 15 years, MME has a reputation for excellent, professional medical equipment at an affordable price. MME staffs only the brightest military-trained and certified biomedical technicians to restore premium equipment to like-new condition and offer that equipment WORLDWIDE for almost half the price.

Savvik Savings

Written by Amanda Riordan on . Posted in Member-Only.

There are 11 FREE seats left for Savvik Members to attend the Lifeguard: Train-the-Trainer Workshop.

Register soon; they’re going fast!

 

In times of crisis, three priorities become paramount: protection, connection, and collaboration. Generark wants to be your source of security in unnerving situations by providing a reliable source of power that will enable you to stay protected and running and allow you to stay connected.

You have enough to worry about in an emergency, but now with Generark you can cross some of those worries off your list!

Reliable, durable, and portable, always have your “ark” with Savvik’s newest vendor, Generark.

Now available in the Savvik Store.

Airgas Healthcare is the leading supplier of the most comprehensive range of gases, gas supply modes, gas delivery systems, and related products and services in the U.S. Their mission is to support our healthcare customers in their mission to improve lives.

Savvik Members can save on Airgas by using our contract!
Savvik Members SAVE on medical supplies through our publicly bid contract with Henry Schein.

Resuscitator Bag Valve Mask

$11.54  $8.89

Disinfectant Surface Wipe Super Sani-Cloth Large Canister 160/Pk

$7.59  $4.38

Smart CapnoLine® etCO2 Sampling Lines

$9.88  $5.80

Electrode Electrocardio BlueSensor 38mm 10/Pk,

$5.29  $2.68
About us
Savvik is a non-profit formed to reduce financial impact within the Public Safety industry. Our mission is to provide members with a mechanism to achieve cost reductions – valuing quality supplies and equipment for members at the industry’s best prices.

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EMS Week Featured Service Application

Written by AAA Staff on . Posted in AAA HQ, Events, Member-Only, News, Press.

EMS Week will take place from May 16–22, 2021.  To celebrate the extraordinary contributions of ambulance services to the communities they serve, we will be featuring specific services throughout EMS week on AAA’s website and social media.

If you would like to apply to have your service featured, please complete and submit all fields below by May 12. Thank you for your service to your community!

 

 

 

AAA Sends Letter to CMS on COVID-19 Response

Written by on . Posted in Government Affairs, Legislative, Member Advisories, Member-Only, News, Regulatory.

The AAA has sent a letter to CMS on how the agency can most help ground ambulance service providers and suppliers be better prepared to respond to potential cases of COVID-19. The AAA has requested priority access to personal protection equipment for EMS personnel and COVID-19 test kits and results, as well as easing Medicare and Medicaid policies on alternative destinations and treatment in place. The letter was also sent to the National Highway Traffic Safety Administration (NHTSA) and the Assistant Secretary for Preparedness and Response (ASPR). Read the letter HERE.

Read the Letter

President signs law providing funds to combat Corona Virus

Written by on . Posted in Government Affairs, Legislative, Member Advisories, Member-Only, News.

President Donald Trump today signed H.R. H.R. 6074 into law, approving $8.3 billion in supplemental appropriations to fund programs in response to the COVID-19 illness. The bill would bolster vaccine development, research, equipment stockpiles, and state and local health budgets as government officials and health workers fight to contain the outbreak, which has claimed 11 lives in the U.S. and sickened more than 160 people across more than a dozen states.

The AAA advocated to negotiators of the bill that first responders needed to be included in the funding package and that all communities be eligible for the funding. Due in part to our outreach, the emergency funding provides a transfer of no less than $10 million to the National Institute of Environmental Health Sciences for worker-based training aimed at preventing exposure of the virus to emergency first responders, and others at risk of exposure (i.e., hospital employees).

The supplemental also appropriates $1 billion for state and local preparedness, which will allow state and local governments to carry out preparedness and response activities, with each State receiving a minimum of $4 million. Of the $1 billion, $300 million is allocated for global disease detection and emergency response, and FY 2019 Public Health Emergency Preparedness grantees.

Member Advisory: CMMI Releases Initial List of ET3 Participants

Written by Tristan North on . Posted in ET3, Government Affairs, Member Advisories, Member-Only, News, Regulatory, Reimbursement.

The Centers for Medicare and Medicaid Services (CMMI) has released its initial list of applicants selected to participate in the ET3 pilot program. CMMI notes that the list is not final as it still needs to execute participation agreements with the applicants. CMMI will issue a final list once it completes the process.

Applicants from 36 states and the District of Columbia were selected to participate in the program. Approximately 200 applicants were approved with instances in which the same ambulance service organization submitted applications for multiple counties as well as more than one organization submitting an application for the same county. CMMI has sent notifications to each of the applicants letting them know to expect a follow up email with the partnership agreement, program guidance and additional details.

The ET3 program is a five-year voluntary pilot program designed to test the potential benefit to the Medicare program and patients of ambulance service providers and suppliers furnishing treatment in place as well as transport to alternative destinations. For more information about the ET3 program, please go the ET3 website.

House Committees Consider Balance Billing Proposals

Written by Tristan North on . Posted in Balance Billing, Member Advisories, Member-Only, News, Reimbursement.

This past Tuesday and Wednesday, respectively, the House Ways & Means and Education & Labor Committees marked up their proposals on balance or “surprise” billing. As we reported on Monday of this week, the Ways & Means Committee proposal, the Consumer Protections Against Surprise Medical Bills Act (H.R. 5826), did not include a provision on ground ambulance services. The House Education & Labor proposal, The Ban Surprise Billing Act (H.R. 5800), however, included a provision to create a federal advisory committee to recommend restrictions on the ability of ground ambulance service providers and suppliers to balance bill.

The Ways & Means Committee reported out H.R 5826 favorably by voice vote. While the Education & Labor Committee also reported out H.R. 5800 favorably, the vote was 30 to 13 as a block of its Committee members preferred the approach of the Ways & Means proposal on how to address balance billing for other providers. It is now up to House leadership to determine next steps on how the chamber will approach a final package on balance billing.

While H.R. 5800 as reported out by the Education & Labor Committee still includes the provision on ground ambulance services, Chairman Scott (D-VA) and Ranking Member Foxx (R-NC) prior to mark up had removed the most problematic language in the bill. As introduced, H.R. 5800 would have given the Department of Health and Human Services the authority to issue regulations to restrict balance billing based on the findings of the advisory committee. This would have eliminated federal lawmakers from being able to evaluate the recommendations prior to the changes being implemented. The language was removed in the chairman’s mark of the bill, and thus the Congress would now have an opportunity to debate and craft legislation on the recommendations.

The AAA along with the International Association of Fire Chiefs (IAFC), International Association of Firefighters (IAFF) and National Association of EMTs (NAEMT) had advocated against the ground ambulance provision. We thank Chairman Scott, Ranking Member Foxx and members of the Committee for listening to our concerns and removing the regulation authority language.

Only one of the four pieces of legislation on balance billing reported out by congressional committees includes a provision on ground ambulance services. We will continue to advocate to preserve the ability of local governments to determine the rates and standards for their EMS systems and against the inclusion of a ground ambulance provision in a final package on balance billing.

We will keep you apprised of new developments on the issue.

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