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

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

 

NEMSM Board of Directors Announced

From the National EMS Museum

In October 2022, The National EMS Museum Board of Directors made a progressive and far-reaching decision to re-image the function and direction of the Museum and its Board of Directors. At that time, the Board decided to announce an initiative to reach out to more communities to recruit a diverse and interested group of leaders that could aggressively move the Museum forward through new strategic initiatives. After an extensive search and interview process conducted by an independent review panel, The National EMS Museum is pleased to announce the new members of The National EMS Museum Board of Directors with skills in EMS, museum management, fundraising and sponsorship development:

Larry J. Appel, M.B.A., EMT joins the NEMSM Board of Directors with 45 years of experience in EMS as an EMT.  His experiences include non-profit director, business owner, manager of several Maryland-based commercial ambulance services, paid 911 EMS provider, V.P. of Ambulance Sales for FR Conversions, and currently the EMS Business Development Manager for Bioquell (An Ecolab Solution).

Fred Claridge is retired and living in North Carolina after a 41-year career in EMS and emergency management. He served as a field provider, EMS instructor, and administrator, including directing one of the largest EMS systems in the country, as well as service as an emergency planner. Additionally, Fred has served as the inaugural editor of the EMS Historian: The Journal of The National EMS Museum.

Fred is serving at the National EMS Museum Vice President, 2023-2025

Elyssa Gonzales is a Master of Arts candidate at Johns Hopkins University for Museum Studies and Nonprofit Management with an additional focus on understanding museum operations and the continuing value to their communities. Her interests lay in supporting the building and/or restructuring museums from the ground up and to help museums find their unique way of supporting their communities.

J. Sam Hurley, MPH, EMPS, NRP currently serves as the Director of Maine’s Bureau of Emergency Medical Services. Sam began his career in EMS in North Carolina at a small rural volunteer fire department and subsequently continued his involvement with EMS throughout his undergraduate studies at the University of North Carolina at Chapel Hill and graduate school at Emory University, where he worked for Grady Health System in downtown Atlanta.

Cindy Kessler holds a Bachelors of Science in Design and has worked in various positions with museums, aquariums, and nonprofit organizations for the better part of three decades. Outside of her nonprofit work, Cindy is an avid singer, having performed at Carnegie Hall and The Kennedy Center. She is also a writer and artist, and enjoys directing youth theater performances in her spare time.

Cindy is serving at the National EMS Museum Secretary, 2023

Christopher Montera has more than 34 years of experience in Paramedic Services, Public Health, and the Fire Service. He is the Director of State and Federal Programs for ESO and the former Chief Executive Officer at Eagle County Health Service District and holds a Master’s in Health Leadership.

Chris is serving at the National EMS Museum Treasurer, 2023

Gary M. Schindele has been an EMT for 47 years and is a leading subject matter expert in the field of emergency preparedness design and implementation and serves as a member of the Central Florida Disaster Medical Coalition. Gary also volunteers as the Public Affairs Officer for the United States Naval Sea Cadet Corps youth program. Gary is also the President and Owner of Paladin Healthcare LLC which manufactures the original Fairfield Equipment Rail, once the standard for Equipment Management in most ambulances back in the late 70’s and 80’s.

Dave Zaiman has been in and around EMS for over 30 years. He spent 15 years working in the field as an EMT, EMD, and Paramedic. Dave finished his career at Hennepin County Medical Center in Minneapolis MN. Since then, Dave has held several leadership roles in the healthcare technology industry. Dave currently serves as Pulsara’s VP Sales – Midwest.

Dave is serving at the National EMS Museum President, 2023-2025

Alan DeYoung is the current Executive Director of the Wisconsin EMS Association with a passion for strategic development and business marketing.  Alan will serve as an Ex-Officio member of the Board of Directors as the Immediate Past President, 2023-2025.

The Board of Directors will continue to be supported by Kristy Van Hoven (Museum Director), Tom Scott (Accounting), and the incredible volunteers of this organization. We invite anyone interested in volunteering to reach out to the Board of Directors at board@emsmuseum. org or Kristy at director@emsmuseum. org.

The National EMS Museum is a volunteer-led organization that collects, preserves, and shares the history of emergency medical response in the United States to celebrate the contributions of providers across the country and inspire future professionals to take up the call. To learn more about The National EMS Museum, please visit emsmuseum.org.

NREMT | In Memoriam: Rocco V. Morando leaves a rich legacy for EMS

 

Rocco V. Morando, the Founder and first Executive Director of the National Registry of Emergency Medical Technicians passed away peacefully and surrounded by family on the morning of February 21, 2023 after a prolonged illness. He was 95.

“It is with a heavy heart and deep sadness that I inform you of the passing of our organization’s founder,” Bill Seifarth, the current executive director of the organization announced to his staff and board this afternoon. “Rocco Morando was a luminary in the EMS profession and was instrumental in helping shape the lifesaving system we know today. His legacy will continue to provide inspiration for years to come, and we are grateful for his contributions.”

On June 4, 1970, the National Registry of Emergency Medical Technicians was established following the recommendation of a task force assembled under President Lyndon B. Johnson’s Committee on Highway Traffic Safety. Morando was selected as the National Registry’s founding executive director in 1971 and held that position for nearly two decades.

During his career at the National Registry, Morando oversaw a number of accomplishments, including: the first basic NREMT-A examination administered simultaneously to 1,520 ambulance personnel at 51 test sites throughout the United States (1971);  the first recertification of Nationally Registered EMTs based on re-evaluation of skills (1973); the development of the first national paramedic curriculum in conjunction with leading EMS agencies and the University of Pittsburgh (1976-77);  and the first NREMT-Paramedic examination (1978); the development of the first NREMT-Intermediate curriculum  and examination (1980).

Upon his retirement on December 31, 1988, Morando was honored with a celebration attended by hundreds of friends and representatives from national EMS organizations. The National Registry’s headquarters in Columbus, Ohio was renamed the Rocco V. Morando Building that same year.

The Rocco V. Morando Lifetime Achievement Award, named in his honor, recognizes a lifetime of commitment, contributions and leadership to Emergency Medical Services (EMS). The award is presented by the National Association of EMTs and is sponsored by the National Registry.

Current and former employees, along with those throughout the EMS community, send their thoughts and condolences to Rocco’s family and friends.

Funeral arrangements are still being made at this time. More information will be available on the funeral home’s website.

CONFIDENTIALITY NOTE: This e-mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this e-mail message is not the intended recipient, or the employee or agent responsible for delivery of the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is prohibited. If you have received this e-mail in error, please notify us immediately by telephone at (614) 888-4484 and also indicate the sender’s name. Thank you, National Registry of EMTs.
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This Week’s Savvik Deals

Cost Collection is coming. Is your organization prepared?

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The Cost Collection workshops are coming to

  • St. Charles, MO – February 8th 2023
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CAAS Announces Interim Administrator for Ground Vehicle Standard (GVS)

Driven to a Higher Standard

 

 

 

CAAS Announces Interim Administrator for Ground Vehicle Standard (GVS)

For Immediate Release
 

GLENVIEW, ILLINOIS – February 2, 2023 – The Commission on Accreditation of Ambulance Services (CAAS) is pleased to announce that Mark Postma has accepted the position of Interim Administrator for CAAS’s Ground Vehicle Standard.  Mark Postma succeeds Mark Van Arnam, who held the Administrator position from the inception of the Ground Vehicle Standard in 2014.  Van Arnam leaves CAAS to take on the role of President of the REV Ambulance Group.

 

CAAS Chair Dale Berry said “CAAS wishes to extend its deep-felt appreciation for the tremendous contributions that Mark Van Arnam has provided over the last 7 years.  Tapping into his significant industry expertise and passion for creating standards that improve ground vehicle safety, Mark Van Arnam was instrumental in establishing the CAAS Ground Vehicle Standard as the emergency transportation’s preferred standard. Our industry is safer because of Mark Van Arnam’s commitment and passion.”

 

In announcing Postma’s new interim role within CAAS, Dale Berry, said; “CAAS is extremely fortunate to have someone with Mark Postma’s experience and leadership abilities to continue the very successful launch and ongoing development of the Ground Vehicle Standard.  Mark Postma has been the CAAS GVS Committee Co-Chair since 2016 and has a depth of knowledge that ensures a seamless transition.  Mark Postma started as a paramedic over 40 years ago and continues as an esteemed leader in the EMS field.”

 

About the CAAS Ground Vehicle Standard (GVS)

 

Starting in 2014, CAAS established a Vehicle Standard Committee to develop consensus-based ground ambulance vehicle standards called GVS. Thanks to the hard work of this broad-based committee, the third significant update to the standard, GVS 3.0, was released in July 2022.
With the release of GVS 3.0, CAAS has strengthened its position as the leader in emergency vehicle standards. The CAAS GVS Standard is designed for use by EMS regulators and providers for use in their vehicle requirement processes.

 

The new ambulance vehicle section of GVS V3.0 contains updates and edits from the prior version, and includes the latest safety, quality, and compliance requirements for new production ambulances. In addition, GVS V3.0 contains a comprehensive Remount Standard. The GVS Remount Standard provides minimum requirements for both Remounters and Remounted Ambulances, including specific requirements for vehicle production processes and quality control.

 

About the Commission on Accreditation of Ambulance Services (CAAS)

 

The Commission on Accreditation of Ambulance Services (CAAS) was established in 1993 to encourage and promote quality patient care in America’s medical transportation system.  CAAS is an independent Commission that established a comprehensive series of standards for the ambulance service industry.

CAAS accreditation signifies that an ambulance service has met the “gold standard” determined by the ambulance industry to be essential in a modern emergency medical services provider. These standards often exceed those established by state or local regulation.  The CAAS standards are designed to increase operational efficiency and clinical quality, while decreasing risk and liability to the organization.
CAAS is an American National Standards Institute (ANSI) Accredited Standards Developer (ASD).

 

 

 

Commission on Accreditation of Ambulance Services (CAAS)

1926 Waukegan Road Phone: (847) 657-6828
Suite 300 Fax: (847) 657-6825
Glenview, Illinois E-mail: CAAS Staff
60025-1770 Website: www.caas.org

REV | Ambulance Industry Veterans to Lead Manufacturing Group

Press Release

BROOKFIELD, WI – January 31, 2023 – The long-time ambulance manufacturing team of
Mark Van Arnam and Randy Hanson have been selected to lead the REV Ambulance Group.
Mark will serve as President for the Group and Randy will function as Chief Operating Officer.
“Mark and Randy have worked together in our company’s ambulance operations for over 35
years” stated Paul Bamatter, Chairman of REV Group’s Board of Directors. “They are well
known as the leading ambulance team in the business.”

The REV Ambulance Group is the largest ambulance manufacturing corporation in the industry,
and consists of legendary brands AEV, Horton, Leader, Road Rescue and Wheeled Coach.
“Our main objective is to provide our customers and dealers the high-quality vehicles that they
need and that we are known for,” Bamatter added. “We believe this new leadership team will
take our ambulance group to the next level.”

###

About REV Group, Inc.
REV Group companies are leading designers and manufacturers of specialty vehicles and
related aftermarket parts and services, which serve a diversified customer base, primarily in the
United States, through three segments: Fire & Emergency, Commercial, and Recreation. They
provide customized vehicle solutions for applications, including essential needs for public
services (ambulances, fire apparatus, school buses, and transit buses), commercial
infrastructure (terminal trucks and industrial sweepers), and consumer leisure (recreational
vehicles). REV Group's diverse portfolio is made up of well-established principal vehicle brands,
including many of the most recognizable names within their industry. Several of REV Group's
brands pioneered their specialty vehicle product categories and date back more than 50 years.
REV Group trades on the NYSE under the symbol REVG.

Media:
Julie Nuernberg
Director of PR & Social Media
+1.262.389.8620 (mobile)
julie.nuernberg@revgroup.com

Employee Retention Tax Credit Quick Take

Recently, members have asked numerous questions about the COVID-19-related Employee Retention Tax Credit (ERTC).  HR/Operations Consultant Scott Moore, Esq., addresses common areas of confusion and shares information about the ERTC program in this Quick Take.

 

US Ambulances for Ukraine

As we start the new year, US Ambulances for Ukraine continues to actively seek donated used ambulances from across the United States to send to Ukraine.  Since the full-scale invasion of Ukraine by Russia on February 24, 2022, US Ambulances for Ukraine, in collaboration with the Ukrainian Consulate in Chicago has successfully delivered 18 American ambulances to Ukraine, many coming from members of the American Ambulance Association.  In addition, another 10 ambulances and one fire engine are sailing across the Atlantic Ocean and will soon be delivered to Ukraine.  Efforts are currently underway to make the next shipment of donated American ambulances the largest to date.  The goal is to secure 22 ambulances to be shipped in late January or early February, which would bring the total number of donated ambulances from the United States to 50.  If you have an ambulance that is mechanically sound that you are considering retiring or have one that isn’t needed anymore and would like to participate in this effort US Ambulances for Ukraine would love to hear from you.  This group has a proven track record of successfully delivering ambulances to hospitals, military units, NGOs, fire departments and other entities operating in Ukraine. The group also continuously updates donors during the process and provides photographic updates of the ambulances once they have been delivered.  Every donor knows exactly where their ambulance will be donated before it even leaves the United States.

The American Ambulance Association has followed the Twitter feed of US Ambulances for Ukraine @AmbulancesU and encourages you to do so as well.  There you can see the latest updates on their efforts and several images of donated American ambulances in action.  If you are interested in donating an ambulance or would like more information you can reach out to the founder of US Ambulances for Ukraine, Chris Manson, Vice President of Government Relations for OSF HealthCare at Christopher.M.Manson@osfhealthcare.org.  

DOJ OJP | Law Enforcement Congressional Badge of Bravery

Learn More or Nominate Now

Every day, federal, state, and local law enforcement officers engage in exceptional acts of bravery while in the line of duty. Often, such acts place the officers involved at personal risk of injury or result in their sustaining a physical injury. To honor these acts of bravery, Congress passed the Law Enforcement Congressional Badge of Bravery Act of 2008 (Public Law 110-298), creating the Federal Law Enforcement Congressional Badge of Bravery and the State and Local Law Enforcement Congressional Badge of Bravery. The act establishes an award to honor exceptional acts of bravery in the line of duty by federal, state, and local law enforcement officers. The medals are awarded annually by the U.S. Attorney General and are presented by the recipients’ Congressional representatives.

To meet the definition of an act of bravery, nominees for the Congressional Badge of Bravery must have either:

  1. Sustained a physical injury while engaged in the lawful duties of the individual, and performing an act characterized as bravery by the agency head who makes the nomination, and being at personal risk; or
  2. Although not injured, performed an act characterized as bravery by the agency head who makes the nomination that placed the individual at risk of serious physical injury or death.

Nominating a Law Enforcement Officer to Receive the Congressional Badge of Bravery

The submitting of nominations is by/at the direction of law enforcement agency heads to the Department of Justice, Office of Justice Programs, Bureau of Justice Assistance. Nominations are considered by either the Federal Law Enforcement Congressional Badge of Bravery Board or the State and Local Law Enforcement Congressional Badge of Bravery Board, which submit their recommendations to the U.S. Attorney General.

The opening date for nominations is on or about December 15 of each year. When the nomination period is open, all nominations must be submitted through the online Congressional Badge of Bravery Nomination System.

PLEASE NOTE: The background of Congressional Badge of Bravery nominees may be reviewed as part of the selection process. Agency heads must submit nominations through the online Congressional Badge of Bravery Nomination System.

More Information

Learn More or Nominate Now

Letter to VA Reimbursement of Ambulance Services

The AAA has sent a letter to VA Secretary Denis McDonough asking him to delay the implementation of a final rule that would allow the Department of Veterans Affairs (VA) to reimburse at the lower of billable charges or Medicare rates for certain non-contracted ambulance services. The proposed rule was issued back in 2020 but we understand that the VA could now issue the final rule in January 2023. GMR has been advocating on Capitol Hill for a delay in air and ground ambulance services. The AAA will be issuing later today a request for AAA members to reach out to the VA to also request the delay.

 

December 12, 2022

The Honorable Denis McDonough
Secretary of Veterans Affairs
U.S. Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420

Dear Secretary McDonough,

The American Ambulance Association (AAA) respectfully requests that the Department delay release and implementation of the final rule on the “Change in Rates VA Pays for Special Modes of Transportation (RIN 2900-AP89).” Reimbursing for services to veterans at Medicare rates would have dire consequences for the ability of ground ambulance service organizations to provide lifesaving 9-1-1 emergency and also interfacility ambulance services not only to veterans but entire communities. We ask that the Department delay the rule until after Congress has had an opportunity to act on the results from the Medicare ambulance data collection system which is currently underway.

As documented by the Government Accountability Office (GAO) in 2007 and 2012, the Medicare program reimburses ground ambulance service organizations below the cost of providing their services when temporary add-ons are not considered. Since 2012, the disparity between the cost of providing ambulance services and reimbursement by Medicare has only increased through sequestration cuts, a reduction in inflation updates, and other Medicare payment policy changes. Ground ambulance service organizations are already facing difficult financial straits and cannot
sustain a reduction in reimbursement from another federal payor.

Ground ambulance service organizations serve as the foundation for emergency medical response for veterans and communities throughout the country. Our members are a vital component of our local and national health care and 9-1-1 emergency response systems and serve as lifelines of medical care for many rural and underserved communities. However, our ability to continue to serve communities is already at risk due to inadequate reimbursement and access to care for veterans would be further jeopardized if the Department were to reimburse at lower levels for ground ambulance services.

The AAA is the primary association for ground ambulance service organizations, including governmental entities, volunteer services, private for-profit, private not-for-profit, and hospital-based ambulance services. Our members provide emergency and non-emergency medical transportation services to more than 75 percent of the U.S. population. AAA members serve
patients in all 50 states and provide services in urban, rural, and super-rural areas.

Again, we request that you delay the release and implementation of the final rule on the “Change in Rates VA Pays for Special Modes of Transportation”.

If you have any questions regarding our request, please do not hesitate to have a member of your staff contact AAA Senior Vice President of Government Affairs Tristan North. Tristan can be reached by phone at (202) 802-9025 or email at tnorth@ambulance.org.

Thank you in advance for your consideration.

Sincerely,

/AAA - AmerAmbAssoc Team Folder/Signatures/Baird, Shawn Signature.png
Shawn Baird
President

CMS Posts 2023 Public Use File

On November 23, 2022, CMS posted the 2023 Ambulance Fee Schedule Public Use Files. These files contain the amounts that will be allowed by Medicare in the calendar year 2023 for the various levels of ambulance service and mileage. These allowable reflect an 8.7% inflation adjustment over the calendar 2022 rates. The 2023 Ambulance Fee Schedule Public Use File can be downloaded from the CMS website by clicking here.

Please note that these files reflect the Medicare allowable based on current federal law.  Accordingly, the 2023 Public Use Files do not include the current add-ons (i.e., 2% for urban, 3% for rural, and the super-rural bonus), as these add-ons are currently scheduled to expire on December 31, 2022.

The AAA is actively working with congressional offices to not only extend but hopefully increase, the Medicare ambulance add-ons by the end of the year. If you have not already written to your members of Congress about extending the add-ons at increased levels, please do so today by using the AAA online advocacy tool by clicking here.

Unfortunately, in recent years, CMS has elected 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 will be publishing a reformatted version of the CMS Medicare Ambulance Fee Schedule that includes the state and payment locality headings. The reformatted fee schedule will be available on the AAA website in the coming days.

The AAA will also be publishing an updated version of its Medicare Rate Calculator, which we expect to have available on our website once we have a better sense of the timing of the extension of the add-ons.

CMS Update-CY 2023 Final Ambulance Fee Schedule

Member Advisory:  CMS Issues CY 2023 Final Ambulance Fee Schedule Rule Updated Data Ground Ambulance Data Collection System

by Kathy Lester, JD, MPH

CMS has released the “CY 2023 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicare and Medicaid Provider Enrollment Policies, Including for Skilled Nursing Facilities; Conditions of Payment for Suppliers of Durable Medicaid Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS); and Implementing Requirements for Manufacturers of Certain Single-dose Container or Single-use Package Drugs to Provide Refunds with Respect to Discarded Amounts” (Final Rule).  The Final Rule includes proposals affecting ground ambulance services in terms of medical necessity requirements and documentation requirements, as well as to the ground ambulance cost collecting tool.

I.           Medical Necessity and Documentation Requirements for Nonemergency, Scheduled, Repetitive Ambulance Services

              CMS finalizes the modifications to the documentation requirements codified in regulation pertaining to the medical necessity and documentation requirements for nonemergency, scheduled, repetitive ambulance services, such as those to/from dialysis facilities.  The Final Rule clarifies that the Physician Certification Statement (PCS), and additional documentation from the beneficiary’s medical record, may be used to support a claim that transportation by ground ambulance is medically necessary.  It also notes that the PCS and additional documentation must provide detailed explanations that: (1) are consistent with the beneficiary’s current medical condition; and (2) explain the beneficiary’s need for transport by an ambulance.  Coverage includes observation or other services rendered by qualified ambulance personnel.  It maintains the following requirements:

  • In all cases, the provider or supplier must keep appropriate documentation on file and, upon request, present it to CMS;
  • The ambulance service must meet all program coverage criteria including vehicle and staffing requirements; and
  • A signed PCS does not alone demonstrate that transportation by ground ambulance was medically necessary.

             CMS declines to “confine this regulatory clarification to the RSNAT prior authorization program, as there may be non-emergent, scheduled, repetitive ambulance transport services outside of that program that would be affected.” (Display Copy 1756)  CMS also does not provide further clarification about what it means by the term “additional documentation” because it believes that “the data elements needed will vary depending upon the beneficiary’s specific conditions and needs.” (Id.)  CMS also states that “[t]his proposal does not establish new obligations for documentation; rather, it merely clarifies existing requirements.” (Id. at 1757).  In response to a comment, CMS also writes, “In addition, our pre-proposal language and proposed regulatory language both reflect that the presence of a PCS alone is not sufficient to demonstrate medical necessity, and, therefore, must be supported by medical documentation.” (Id.)  CMS also declined to extend authorization to nurse practitioners and physicians’ assistants, stating that to do so would be outside of the scope of the rule.

II.         Ground Ambulance Data Collection Instrument

            CMS finalizes the proposed changes to the ground ambulance data collection instrument and instructions with a few additional modifications in response to comments.  They fall within four areas:  (1) editorial changes for clarity and consistency; (2) updates to reflect the web-based system; (3)  clarifications responding to feedback from questions from interested parties and testing; and (4) typos and technical corrections.  The updated instrument that includes all of the CY 2023 proposed changes to review and provide comments on is posted on the CMS website at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AmbulanceFeeSchedule/Downloads/Medicare-Ground-Ambulance-Data-Collection-System-Instrument.pdf.

            One of these modification is to Section 5, Question 3c, which now reads: Does your organization respond to calls with another non- transporting agency such as a local fire department that is not part of your organization? After the question, the following instructions will be provided: This includes joint responses with other ground ambulance organizations as well as cases where a fire, police, or other public safety department responses to calls for service with your organization. Only consider cases where your ground ambulance does or would have transported the patient, if necessary.

            The Final Rule notes that the system already includes an “autosave” feature that saves responses as they are entered. The system also allows the same user to enter information at different times, and/or multiple users to enter information at different times. The system also already includes many validation and error checking steps that are automatically applied as respondents enter information. CMS also noted that it has no plans to adopt additional import functionality prior to the launch of the system, but that it will continue to explore the option of an API.  CMS also indicates that the final written tool and web-based platform will align before the system goes live.  A print function will also be available for the online submissions.

            CMS indicates that the data from the collection system will be made available to the public through posting on the CMS website at least every 2 years.  Summary results will be posted by the last quarter.  The data collected under the ground ambulance data collection system will be publicly available beginning in 2024.

            CMS also indicates that it will not require a ground ambulance organization to fill the data entry submitter and data certifier roles with different individuals.

            CMS has also provided additional guidance, including FAQs available at:  https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/AmbulanceFeeSchedule/Downloads/Medicare-Ground-Ambulance-FAQs.pdf.

            CMS also finalizes its proposal for an automated process for submitting a hardship exemption request and informal review request.

III.        Origin and Destination Requirements Under the Ambulance Fee Schedule

            In the Final Rule, CMS also responds to comments it received on the Interim Final Rule that expanded the origin and destination requirements.  It finalizes the interim final policy that the expanded list of covered destinations for ground ambulance transports including, but are not limited to, any location that is an alternative site determined to be part of a hospital, CAH or SNF, community mental health centers, FQHCs, RHCs, physician offices, urgent care facilities, ASCs, any location furnishing dialysis services outside of an ESRD facility when an ESRD facility is not available, and the beneficiary’s home.  The policy will be In effect for the duration of the PHE for the COVID-19 only.

OSHA Publishes Mental Health Resources

OSHA Publishes Resources to Assist Employers with Mental Health & Wellness

The United States Department of Labor Occupational Safety & Health Administration has posted numerous resources and tools for employers to utilize to combat workplace stress.  OSHA has published these resources following a survey conducted by the American Psychological Association in 2021 that reported burnout and stress at an all-time high across all professions and that “actions from their employers would help their mental health.”

The resources published by OSHA include:

  1. Guides for Employers for both Senior Managers and Frontline Supervisors
  2. Mental Health Checklists for Senior Managers and Frontline Supervisors
  3. Workplace Stress Sample Survey Questions
  4. Myth Buster Fact Sheets about Workplace Stress
  5. Workplace Postings regarding Workplace Stress & Mental Health
  6. Public Service Announcements on Suicide Prevention Month
  7. Training Resources for Employers

Employers are starting to recognize the impacts that worker mental health has in the workplace.  Statistics cited by OSHA reveal that workplace stress has been reported to cause 120,000 deaths in the U.S. each year.  Nearly 83% of workers suffer from work-related stress and more than half of those report that workplace stress impacts their home life.  Importantly, for every $1.00 spent on ordinary mental health concerns, employers see a $4.00 return in productivity gains.

The American Psychological Association encourages employers to develop mental health and wellness programs in the workplace.  They recommend that employers go beyond simply offering an Employee Assistance Program (EAP). They recommend a cross-departmental review of your company’s EAP offerings to assess if they are meeting your workforce needs.  Also, ensure that your program includes mental health professionals from diverse backgrounds and specialties.  Additionally, they encourage launching a communications campaign about the things that your EAP professionals can cover, including stress, mental health, and financial guidance. Most importantly, ensure that your frontline leaders are informed and able to communicate the EAP availability and offerings to your team.

Under the Mental Health Parity and Addiction Equity Act (MHPAEA), all employers sponsored health plans are required to offer the same level of health coverage for mental health-related concerns as for any other medical concerns. Most short- and long-term disability insurance plans offer a limited number of free Employee Assistance Plan visits as part of the included benefits. Lastly, American Ambulance Association members get free access to the Counselor Match Program, which provides access to mental health counselors with extensive experience in working with EMS and public safety professionals.

If you need assistance with this, or any other workplace challenges, please contact the AAA at hello@ambulance.org.

CMS Announces 2023 Ambulance Inflation Factor

On October 14, 2022, CMS issued Transmittal 11642 (Change Request 12948), which announced the Medicare Ambulance Inflation Factor (AIF) for the calendar year 2023.

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 the 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 2022, the Federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U increased by 9.1%.  CMS further indicated that the CY 2023 MFP would be 0.4%.  Accordingly, CMS indicated that the Ambulance Inflation Factor for the calendar year 2023 will be 8.7%. 

This is the largest inflation update since the implementation of the current Medicare Ambulance Fee Schedule in April 2002.  The increase from last year’s 5.1% increase is also the single largest year-over-year increase on record.

Administration Includes Ambulance Add-Ons Extension on CR List

The Biden Administration has issued a list of expiring programs and items that they would like to see or have no objection to being, extended as part of the FY2023 Continuing Resolution.  The list includes “Medicare add-on payments for ground ambulance services”. The list also includes a “Suspension of Medicare Sequestration” on which the AAA has been advocating. Congress will need to pass a CR by September 30 to avoid a partial government shutdown.

No determination has been made by congressional decision-makers as to when Congress will address Medicare extenders that expire at the end of the year but most key congressional staff believe extenders will be addressed after the election. Even if extenders are not included in the CR, the list demonstrates the overall support and/or recognition of the Administration for the listed programs and items including the Medicare ambulance add-on payments and suspension of sequestration.

Authorization Issues

Note: The following list is provided for your information. In the event that authorizing
legislation is not enacted in a timely manner, these items will allow either for the
continuation of programs that will be funded in the continuing resolution (CR) or for other
legislative fixes.

Agriculture/Rural Development:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Agriculture, Livestock Mandatory Reporting

No Objection to Inclusion in a CR if Not Enacted First in Other Legislation
HHS, FDA User Fees
HHS, Exclusivity of Certain Drugs Containing Single Enantiomers
HHS, Medical device programs expiration: 1) Authority to accredit 3rd parties to review certain medical device applications; 2) Conformity Assessment Pilot Program for Devices; 3) Device Postmarket Pilot Projects; 4) Inspections by Accredited Persons; 5) Modification to Humanitarian Device Exemption

Commerce/Justice/Science:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Justice, Additional Special Assessment (Expires 9/11/22)
Justice, U.S. Parole Commission (NOTE: Extension for two years is recommended)
Justice, Protection of certain facilities and assets from unmanned aircraft (Also DHS)
Justice, Extending Temporary Emergency Scheduling of Fentanyl Analogues Act (Expires 12/31/22)

Defense:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Defense, North Atlantic Treaty Organization Security Investment Program (NSIP)
Defense, Authority to Provide Temporary Adjust in Rates of Basic Allowance for Housing (BAH) if the Actual Costs of Adequate Housing for Civilians in That Military Housing Area or Portion Thereof Differs from the Current BAH Rates by More than 20 Percent
Defense, Authority for reimbursement of certain coalition nations for support provided to United States military operations (Expires 12/31/22)
Defense, Authority to provide assistance to counter the Islamic State in Iraq and Syria (Expires 12/31/22)
Defense, Authority to provide assistance to the vetted Syrian groups and individuals. (Expires 12/31/22)
Defense, Authority to provide temporary increase in rates of Basic Allowance for Housing (BAH) under certain circumstances (Expires 12/31/22)
Defense, Authority to Support Operations and Activities of the Office of Security Cooperation In Iraq (Expires 12/31/22)
Defense, Authority to waive annual limitation on premium pay and aggregate limitation on pay for Federal civilian employees working overseas (Expires 12/31/22)
Defense, Extension of Certain Expiring Bonus and Special Pay Authorities (Expires 12/31/22)
Defense, Income Replacement Payments for Reserve Component Members Experiencing Extended and Frequent Mobilization for Active Duty Service (Expires 12/31/22)

No Objection to Inclusion in a CR if Not Enacted First in Other Legislation
Defense, Information Operations, and Engagement Technology Demonstrations
Defense, One-time Uniform Allowance for Officers Who Transfer to the Space Force
Defense, Increased Percentage of Sustainment Funds Authorized for Realignment to Restoration and Modernization at Each Installation
Defense, Pilot Program for the Temporary Exchange of Cyber and Information Technology Personnel
Defense, Reauthorization of Authority to Order Retired Members to Active Duty in Highdemand, Low-density Assignments

Financial Services/General Government:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
FCC, FCC General, and Incentive Auction Authority Continuation (NOTE: Extension of auction authority through 9/30/2024 is recommended)
GSA, Pilot Programs for Authority to Acquire Innovative Commercial Items Using General Solicitation Competitive Procedure (NOTE: also covered by DHS)
SBA, Assistance for Administration, Oversight, and Contract Processing Costs
SBA, Commercialization Readiness Pilot Program for Civilian Agencies
SBA, Phase 0 Proof of Concept Partnership Pilot Program
SBA, Pilot Program to Accelerate DOD Awards
SBA, SBIR Commercialization Assistance Pilot Programs
SBA, SBIR Phase Flexibility
SBA, Small Business Innovation and Research (SBIR)
SBA, Small Business Technology Transfer (STTR)

Homeland Security:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Homeland Security, DHS Joint Task Forces
Homeland Security, E-Verify Program
Homeland Security, National Computer Forensics Institute
Homeland Security, National Flood Insurance Program
Homeland Security, Raising the H-2B Cap
Homeland Security, National Cybersecurity Protection System (NCPS) Authorization, including EINSTEIN
Homeland Security, Counter Threats Advisory Board
Homeland Security, Pilot Programs for Authority to Acquire Innovative Commercial Items Using General Solicitation Competitive Procedure (NOTE: also covered by GSA)
Homeland Security, Protection of certain facilities and assets from unmanned aircraft (Also DOJ)

No Objection to Inclusion in a CR if Not Enacted First in Other Legislation
Homeland Security, Authority to grant special immigrant status to religious workers other than ministers
Homeland Security, Waiver of Foreign Residence Requirements for Physicians Working in Underserved Areas (“Conrad State 30” Program)

Interior/Environment:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Interior, Omnibus Public Land Management Act of 2009

Labor/HHS/Education:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Labor, Trade Adjustment Assistance (TAA) for Workers Program (Expired 7/1/22)
HHS, TANF
HHS, Promoting Safe and Stable Families Program
HHS, Liability protections for health professional volunteers at community health centers (HRSA)
HHS, Medical Countermeasures Innovations Partner
HHS, Maternal, Infant, and Early Childhood Home Visiting Program
HHS, Interdepartmental Serious Mental Illness Coordinating Committee
HHS, Increase in Medicaid FMAP for territories
SSA, Demonstration Project Authority (Expires 12/31/22)

No Objection to Inclusion in a CR if Not Enacted First in Other Legislation
HHS, Additional support for Medicaid home and community-based services during the COVID-19 emergency (Expired 3/31/22)
HHS, Suspension of Medicare Sequestration (Expired 3/31/22)
HHS, Medicare IPPS adjustment for low-volume hospitals
HHS, Medicare-dependent hospital (MDH) program
HHS, Puerto Rico Medicaid Payment
HHS, Restriction on Alaska Native Regional Health Entities
HHS, Tick-Borne Diseases Working Group
HHS, Exception for eligible professionals based in ambulatory surgical centers with respect to incentives for meaningful use of certified EHR technology (Expires 12/31/22)
HHS, Incentives for Qualifying Alternative Payment Model Participants (Expires 12/31/22)
HHS, Medicare add-on payments for ground ambulance services (Expires 12/31/22)
HHS, Medicare add-on payments for rural home health services (Expires 12/31/22)
HHS, Temporary Increase in Medicare Physician and Non-physician Practitioners Payments (Expires 12/31/22)

Military Construction/VA:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
VA, Adaptive Sports Assistance Program (formerly limited to Paralympics)
VA, Co-Pays for Hospital and Nursing Home Care
VA, Homeless and Seriously Mentally Ill Veterans- Additional Services at Certain Locations
VA, Homeless and Seriously Mentally Ill Veterans- Treatment/ Rehab
VA, Manila, Philippines Regional Office
VA, SAH – Assistive Technology Grants
VA, Transportation of Beneficiaries
VA, Advisory Committee on Minority Veterans
VA, Advisory Committee on Education (Expires 12/31/22)
VA, Advisory Committee on Homeless Veterans (Expires 12/31/22)
VA, SAH for Veterans Temporarily Residing with Family (Expires 12/31/22)

Transportation/HUD:

Necessary For Extension or Inclusion in the CR if Not Enacted First in Other Legislation
Transportation, Next Generation 9-1-1

CMS End of PHE Roadmap

CMS Prepares Providers and Suppliers for the End of the Public Health Emergency:

CMS Issues Updates on the End of Emergency Waivers and Flexibilities Issued during the PHE

By Kathy Lester, J.D., M.P.H.

 

Even though it appears that the Biden-Harris Administration will extend the COVID-19 Public Health Emergency (PHE) for at least another 90 days, CMS has begun the process of preparing for the termination of waivers and flexibilities that have been in effect during the pandemic.  During the PHE, the American Ambulance Association has worked closely with CMS and Congress to make sure that ground ambulance services were prioritized and provided with waivers and flexibilities to support their integral role as a front-line medical response during the pandemic.

 

CMS announced its roadmap for the end of the PHE on August 18.  The roadmap includes a summary of the policies that will terminate at the end of the PHE, but also notes that CMS intends to keep some policies in place even after the PHE ends. Examples of policies that will continue after the PHE is allowed to expire include certain morbidity and mortality reporting requirements on long-term care facilities and certain telehealth services expanded by Congress.

 

In its announcement, CMS indicated particular concern about patient safety.  “As mentioned by Lee A. Fleisher, M.D.; Michelle Schreiber, M.D.; Denise Cardo, M.D.; and Arjun Srinivasan, M.D., in February 17, 2022, New England Journal of Medicine Perspective, ‘Safety has also worsened for patients receiving post-acute care, according to data submitted to the Centers for Medicare and Medicaid Services (CMS) Quality Reporting Programs…’”

 

As part of this announcement, CMS released a fact sheet detailing the current status of the Medicare waivers and flexibilities for ambulance providers and suppliers.  Some of the policies highlighted in this fact sheet include:

 

  • Vaccine Reimbursement Rates: CMS will continue to pay approximately $40 per dose for administering COVID-19 vaccines in outpatient settings for Medicare beneficiaries through the end of the calendar year that the COVID-19 PHE ends.  Effective January 1 of the year following the year that the COVID-19 PHE ends, CMS will set the payment rate for administering COVID-19 vaccines to align with the payment rate for administering other Part B preventive vaccines.  CMS plans to continue to pay a total payment of approximately $75 per dose to administer COVID-19 vaccines in the home for certain Medicare patients through the end of the calendar year that the COVID-19 PHE ends.

 

  • Alternative Destination: CMS indicates that it will include this issue in future rulemaking.

 

  • Treat in Place: CMS indicates that the waiver will end with the end of the PHE.

 

  • Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) Prior Authorization: CMS notes that it has already returned to the full model operations including post-payment reviews of claims submitted during the PHE.

 

  • Signature Requirements: Absent indications of potential fraud and abuse, CMS will not review claims for dates of service during the COVID-19 PHE for compliance with the signature requirements.

 

  • Appeal Flexibilities: CMS will allow some of the flexibilities related to the timing of appears to continue consistent with existing authority for appeals once the PHE ends.

 

The AAA will continue to monitor the PHE and any changes in the waivers and flexibilities specific to ground ambulance services.  We encourage members to reach out to our team if concerns or questions arise as CMS winds down the PHE.

Senate Appropriators Address AAA’s Request for Workforce Assistance

Message from AAA President Shawn Baird

The paramedic and EMT shortage has become a top policy priority of the AAA as we pursue several short and long-term initiatives to address this unprecedented crisis. Over the last several months, the AAA has been working closely with Members of the Senate Appropriations Problem Committee and the Office of the Assistant Secretary for Preparedness and Response (ASPR) to secure a grant program that would assist ground ambulance service organizations in hiring and retaining paramedics and EMTs. I am extremely pleased to report that the Fiscal Year 2023 Senate HHS appropriations package includes the program language for which the AAA has been advocating.

The language in the Senate Report reads:

EMS Preparedness and Response Workforce Shortage Program.— The Committee recognizes that our Nation is facing a crippling EMS workforce shortage which threatens public health and jeopardizes our ability to respond to healthcare emergencies on a timely basis. ASPR should prioritize ensuring a well-trained and adequate ground ambulance services workforce in underserved, rural, and Tribal areas and/or addressing health disparities related to accessing prehospital ground ambulance healthcare services, including critical care transport.

In the House, the AAA’s efforts contributed to House appropriators increasing the ASPR account funding for the Hospital Preparedness Program (HPP) (more than $30 million). We anticipate that ASPR would focus its efforts to address the ground ambulance workforce shortage through the HPP, so this increase in funding is also a critical component of the AAA’s efforts.

Although the appropriations process has many more steps to go through before final passage, having the EMS workforce shortage highlighted in the Senate report is a critical step toward achieving our goal to provide ground ambulance services across the country with the help they need during this unprecedent time.

The AAA will continue to work closely with Congressional champions and the ASPR team as they shepherd this language through the next steps in the process. I would like to thank Chairman Patrick Leahy (D-VT), Chair Patty Murray (D-WA), Senators Bill Cassidy (R-LA), Susan Collins (R-ME), Shelly Moore Capito (R-WV), Cindy Hyde-Smith (R-MS), Jeff Merkley (D-OR) and Ranking Members Richard Shelby (R-AL) and Roy Blunt (R-MO) for championing and supporting the effort.

AAA President
Shawn Baird

 

New EEOC Guidance on COVID-19 Testing

EEOC Issued New Guidance on Employer Mandatory COVID-19 Testing Policies

On July 12, 2022, the Equal Employment Opportunity Commission (EEOC) updated its guidance, What
You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws, which
impacted several long-standing COVID-19-related policies. The most significant policy change in the
latest guidance was related to employer mandatory COVID-19 testing. The updated guidance is not likely
to significantly impact EMS employer testing practices for field personnel, but could for those who work
in administrative or non-patient facing roles.

In the latest guidance, the EEOC changed its previous position that employers could generally require
COVID-19 testing for most employees. The EEOC had previously taken the position that it believed that
COVID-19 viral testing was per se, job-related and consistent with business necessity, regardless of the
employer type. Under the latest guidance, the EEOC is now stating that employers will need to more
closely analyze whether viral testing is job-related and consistent with business necessities. In doing so,
employers should utilize any of these factors:

 The Center for Disease Control (CDC) level of community transmission.
 The vaccination status of employees.
 The degree of breakthrough infections are possible for vaccinated workers.
 The transmissibility of current variants.
 The possible severity of illness from a current variant.

In most instances, EMS employers who require COVID-19 viral testing for field employees for ongoing,
symptomatic, or return to work reasons, are likely to meet the job related and consistent with business
necessity requirement. However, for those employees who are in non-patient-facing roles, it will be far
more difficult to justify mandatory COVID-19 testing and employers should reconsider their position on
mandatory testing.

The guidance also included updates to clarify the timeline factors to consider when handling reasonable
accommodation exceptions for vaccinations and how there could be a reasonable pandemic-related
delay. However, they acknowledged that this is likely less impactful at this point in the pandemic.
Additionally, the guidance highlighted that employers are not under an obligation to engage an
employee who has a serious health condition if the employee has not requested an accommodation
from vaccination.

Many EMS employers are currently required to mandate COVID-19 vaccinations for employees who may
enter or interact with the patients or staff of a covered healthcare facility unless they have a covered
religious or disability-related exemption. After nearly two years of the pandemic and the availability of
COVID-19 vaccinations, those employees who wish to be vaccinated would have done so by now. Those
who remain unvaccinated are doing so by choice.

If you have any questions or concerns regarding the updated guidance or any COVID-19 related
workplace practice, be sure to contact the American Ambulance Association for assistance at
hello@ambulance.org.

AJ+ | No Hospitals, No Ambulances: Inside America’s 911 Crisis


Emergency Medical Services (EMS) like ambulances and hospitals are in crisis in rural America. EMS is not considered an essential service in the same way that fire and police departments are, and so they don’t receive the same funding. Paramedics and EMTs often make half the salary that nurses do.

Join us as we travel to the Mississippi River Delta to see how EMS crews are coping with a collapsing health care system.

Emergency Medical Services (EMS) like ambulances and hospitals are in crisis in rural America. EMS is not considered an essential service in the same way that fire and police departments are, and so they don’t receive the same funding. Paramedics and EMTs often make half the salary that nurses do. Join us as we travel to the Mississippi River Delta to see how EMS crews are coping with a collapsing health care system.

YT Chapters

  • 00:00 – Pregnant And Dying, With No Hospital
  • 03:22 – Paramedics Are Delivering Babies In Ambulances
  • 06:04 – Why Is EMS Not Considered An Essential Service?
  • 07:57 – Why EMS Workers Are Wearing Bulletproof Vests
  • 10:05 – Why Hospitals Are Closing In Rural America
  • 12:07 – What Needs To Change In Mississippi?

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