CFPB Finalizes Rule Prohibiting Inclusion of Medical Debt on Credit Reports
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orOn December 23, 2024, CMS posted a revised version of the CY 2025 Ambulance Fee Schedule Public Use Files on its website. These files contain the Medicare allowed amounts for the various levels of ambulance service and mileage. The file is organized by state, and by payment locality within each state. The 2025 Ambulance Fee Schedule Public Use File can be viewed 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 below.
The American Ambulance Association is also pleased to announce the release of its 2025 Medicare Rate Calculator tool. The AAA believes this is a valuable tool that can assist members in budgeting for the current year. This calculator has been updated to account for recent changes in Medicare policies, including the 2025 Ambulance Inflation Factor and the extension of the temporary adjustments for ground ambulance services (i.e., 2% urban, 3% rural, and super rural bonus) through March 31, 2025. This extension was the result of Section 3203 of the American Relief Act, 2025. Barring further legislation, these temporary adjustments will expire on March 31, 2025.
Note on Medicare Sequestration: Both the Ambulance Fee Schedule Public Use Files and the AAA Medicare Rate Calculator display the current Medicare allowables. Neither takes into account the impact of so-called “budget sequestration” on Medicare payments. By law, the sequester requires Medicare contractors (and Medicare Advantage insurers) to reduce the amounts they pay under the Medicare Ambulance Fee Schedule by 2% (i.e., 2% off the 80% of the Medicare allowable typically paid by the Medicare contractor).
The American Ambulance Association is pleased to release its 2025 State Medicaid Rate Survey. This survey sets forth the fee-for-service Medicaid rates for all 50 states. For each state, the Survey lists the rate paid for each of the following procedure codes:
The rates set out in this survey are based on publicly available information provided by the various state Medicaid agencies. While the AAA has taken steps to verify the accuracy of the information on this Survey, it is possible that the rates provided in the Survey may not reflect changes to a state’s reimbursement policies that have not been made publicly available. These rates may also not reflect any emergency budgetary measures or other temporary reductions imposed by a state.
The AAA’s goal is to make this survey as accurate as possible. Therefore, if you believe the rates for your state are inaccurate, please contact hello@ambulance.org for assistance.
The survey is free to AAA members.
The American Ambulance Association (AAA) is pleased to announce the release of its new state-level whitepaper, Ground Ambulance Balance Billing: Overview and Recommendations. Developed by a collaborative team of industry experts, this comprehensive resource provides an in-depth examination of the complex regulatory landscape surrounding ground ambulance billing and the ongoing challenges of keeping consumers out of the middle of payment disputes. The whitepaper offers an overview of existing state laws, gaps in current policy, and pragmatic recommendations—including standardized payment methods and consumer protections—that can inform both policymakers and EMS providers nationwide.
By sharing promising practices from around the country and highlighting the recent work of the Ground Ambulance and Patient Billing Advisory Committee, Ground Ambulance Balance Billing: Overview and Recommendations underscores the AAA’s commitment to safeguarding patients while supporting fair, sustainable reimbursement for ambulance services. We encourage all EMS stakeholders, insurers, and legislators to review this important paper and join us in shaping policies that protect patients and ensure the ongoing availability of these vital, life-saving services.
(Free to AAA members. $1000 list.)
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On Saturday, December 21, the American Relief Act of 2025 (H.R. 10545) became law and thereby averted a partial federal government shutdown. Of critical importance to ground ambulance service organizations, H.R. 10545 also extends the temporary Medicare ambulance add-on payments of 2% urban, 3% rural and 22.6% super rural through March 31, 2025. In addition, the new law wipes clean the PAYGO scorecard preventing a potential 4% cut in Medicare reimbursement for ground ambulance and other Medicare services.
The House of Representatives passed by a vote of 366 to 34 the Continuing Resolution (H.R. 10545) to extend funding for the federal government just hours before reaching the previous funding deadline of midnight on December 20th. The Senate then passed H.R. 10545 by a vote of 85 to 11 late that evening. The CR funds the federal government primarily at current funding levels through March 14, 2025.
The negotiations on the American Relief Act were extremely tense with a more robust initial legislative package, which would have extended the Medicare ambulance add-ons for two years, being replaced with a slimmer bill with fewer and shorter health care provisions. The extension of ground ambulance service payments ended up being just one of twenty-five provisions in the final 118-page Continuing Resolution, which was originally over 1,600 pages.
The AAA greatly appreciates the advocacy of our champions and supporters on Capitol Hill to ensure that the temporary ambulance payments extension was included in the final CR. We also want to thank our AAA members for reaching out to their members of Congress to request their help with the add-on payments. We will continue to push for a longer extension of the ambulance payments at percentages higher than the current levels upon the expiration of the CR.
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orOn November 21, 2024, the HHS Office of the Inspector General (OIG) issued Advisory Opinion 24-09. The opinion relates to a proposal by a municipal ambulance service to begin billing health insurances for treatment-in-place (TIP) services.
The Requestor historically did not charge patients or their insurance when it would respond to a 911 call and treat the patient at the scene. The Requestor indicated that it was considering the implementation of a charge for TIP services furnished in connection with a 911 response. This charge would be based on the level of care furnished to the patient at the scene, and would not exceed the amounts the Requestor currently charged for the same level of service furnished in connection with an ambulance transport. The Requestor indicated that it would impose this charge for all forms of third-party health insurance (i.e., it would bill both Federal health care programs and commercial insurers); however, the Requestor stated that it would not charge uninsured patients for TIP services. Under the proposed arrangement, the requestor would also agree to accept payment from a patient’s health insurance as payment-in-full, i.e., the Requestor would waive any cost-sharing amounts imposed by the patient’s health insurance.
For background purposes, there currently exists a safe harbor to the Federal anti-kickback statute (AKS) for cost-sharing waivers for emergency ambulance services[1]. To qualify for protection under the safe harbor, certain conditions must be met. These include requirements that: (1) the ambulance provider or supplier be owned and operated by a state, a political subdivision of a state, or a recognized tribal organization, (2) the ambulance provider or supplier provide “emergency responses,” (3) the ambulance provider or supplier offers the reduction or waiver on a uniform basis to all of its residents or tribal members, or to all individuals transported, and (4) that the ambulance provider or supplier not claim the waived amounts as bad debt for payment purposes under a Federal health care program. It is the requirement that the waiver be offered on a uniform basis to “all individuals transported” that created the potential need for the advisory opinion.
In other words, the Requestor was attempting to clarify whether the safe harbor was limited to ambulance transports, or whether the OIG would be willing to extend the protections of the safe harbor to all ambulance services, including TIP service.
As part of its analysis, the OIG first determined that the proposed arrangement would result in remuneration in the form: (1) cost-sharing waivers for TIP services covered by patients with commercial insurers and a handful of Medicare Advantage plans that currently cover TIP services and (2) services provided at no charge to patients that lack health insurance. The OIG further determined that this remuneration would implicate both the Federal anti-kickback statute (AKS) and the prohibition on beneficiary inducements. To reach this conclusion, the OIG noted that the cost-sharing waivers might induce Federal health care program beneficiaries to elect to receive other EMS services from the Requestor. The OIG then determined that the proposed arrangement would not qualify under any of the existing safe-harbors. Specifically, the OIG determined that the proposed arrangement would not fall under the existing safe harbor for emergency ambulance services because TIP services are not currently covered under the Medicare Program or the majority of State Medicaid Programs. The OIG further noted that, even if a State Medicaid Program did cover TIP services, the arrangement would still not qualify for the safe harbor because the safe harbor currently only covers ambulance transportation services.
While not qualifying for protection under an existing safe harbor, the OIG nonetheless determined that the proposed arrangement carried little risk of fraud or abuse. The OIG based this determination on several factors. First, the cost-sharing waiver would be applied to all patients receiving TIP services, regardless of their insurance. Second, because neither Medicare nor the majority of State Medicaid Programs currently cover TIP services, the arrangement would not result in any meaningful costs being incurred Federal health care programs. By contrast, the OIG noted that the arrangement might reduce Federal health care program expenditures, by avoiding the need for ambulance transportation and subsequent hospital care. Third, even in those states where Medicaid paid for TIP services, the arrangement was unlikely to increase utilization of EMS services. Finally, the OIG determined that the cost-sharing waivers were unlikely to “meaningfully affect” a patient’s decision to use the Requestor for further ambulance services, noting that patients’ future EMS usage is more likely to be impacted by other factors, including the patient’s location and the decisions made by a 911 dispatcher. For these reasons, the OIG issued a favorable advisory opinion.
The advisory opinion is notable because it is the first time the OIG has addressed the issue of cost-sharing waivers unrelated to an actual ambulance transport. As part of its opinion, the OIG acknowledged the potential benefits of TIP services, including their potential to decrease overall Federal health care program expenditures. The opinion also suggests that the OIG does not view TIP services as creating new compliance risks distinct from those raised by ambulance transportation in general. Thus, the opinion suggests that if the Medicare Program were to extend its ambulance benefit package to include TIP services at some point in the future, the OIG would likely be open to extending the current safe harbor to cover TIP services as well.
[1] 42 C.F.R. §1001.953(k)(4).
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Tristan North
tnorth@ambulance.org
October 10, 2024
Washington, D.C. — Senator Debbie Stabenow has been honored with the first-ever annual EMS Legacy Award by the American Ambulance Association (AAA) for her exemplary leadership and unwavering commitment to emergency medical services (EMS) during her distinguished tenure in the United States Senate.
The award recognizes Senator Stabenow’s significant contributions to the EMS community, particularly her role in introducing and championing critical legislation. Notably, she was instrumental in the creation of the Ground Ambulance Cost Data Collection System, which enhances transparency and supports the sustainability of ground ambulance services across the nation. Additionally, Senator Stabenow’s efforts led to the successful extension of Medicare Ambulance Add-On payments for five years, a vital support mechanism that helps ensure reliable emergency medical care for Medicare beneficiaries.
The EMS Legacy Award underscores the critical importance of legislative support for emergency medical services, highlighting Senator Stabenow’s role in elevating these issues on the national stage. Her advocacy ensures that EMS providers have the resources and support needed to deliver high-quality care.
About the American Ambulance Association:
The American Ambulance Association is a nonprofit organization that advocates for the interests of ambulance service providers and the patients they serve. With a mission to advance the profession and improve patient care, the AAA provides resources, education, and support to its members and the EMS community.
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tnorth@ambulance.org
October 10, 2024
Congressman Mike Bost Honored with Legislative Recognition Award
from the American Ambulance Association
Washington, D.C. — The American Ambulance Association (AAA) has awarded Mike Bost (IL) a 2024 AAA Legislative Recognition Award in recognition of his leadership in ensuring veterans continue to have access to emergency 9-1-1 and interfacility ground ambulance services.
Congressman Bost introduced the bipartisan VA Emergency Transportation Access Act (S. 2757, H.R. 6433) to direct the Department of Veterans Affairs (VA) to further analyze the impact of the VA Final Rule on Special Modes of Transportation and create an advisory committee to evaluate future reimbursement rates for ambulance services.
The Rule as it stands would reimburse ambulance service providers below the costs of providing medical and transport services. S. 2757 would help ensure that ambulance service providers throughout Kansas and the country do not face further cuts to VA reimbursement which would limit their ability to provide lifesaving emergency medical services to our nation’s veterans.
Due to the efforts of Congressman Bost and a bipartisan group of Senators and Representatives, the VA has recently stated it will delay implementation of the Final Rule for four years which would provide time to determine more fair and adequate payment rates for ambulance services.
“We greatly appreciate the leadership of Congressman Moran in ensuring that our veterans and entire communities will continue to have access to vital ground ambulance service,” said AAA President, Randy Strozyk. “His perseverance paid off with the VA recognizing the need to delay implementation of the final rule to provide more time to address concerns that the new payment system could adversely affect ambulance access for veterans.”
The American Ambulance Association will be presenting Congressman Bost with his Legislative Recognition Award this November at the AAA Annual Stars of Life Event, which honors emergency medical services professionals from around the nation who have gone above and beyond in service to their communities.
FOR IMMEDIATE RELEASE
Contact:
Tristan North
tnorth@ambulance.org
October 10, 2024
Congressman Ryan Zinke Honored with Legislative Recognition Award
from the American Ambulance Association
Washington, D.C. — The American Ambulance Association (AAA) has awarded Congressman Ryan Zinke (MT) a 2024 AAA Legislative Recognition Award in recognition of his leadership in ensuring veterans continue to have access to emergency 9-1-1 and interfacility ground ambulance services.
Congressman Zinke has led efforts to restrict the ability of the Department of Veterans Affairs to implement its Final Rule on Special Modes of Transportation which would reimburse ambulance service providers below the costs of providing medical and transport services to our veterans. Congressman Zinke has supported efforts to instead create an advisory committee to evaluate future VA reimbursement rates for ambulance services.
Due to the efforts of Congressman Zinke and a bipartisan group of Senators and Representatives, the VA has recently stated it will delay implementation of the Final Rule for four years which would provide time to determine more fair and adequate payment rates for ambulance services.
“We thank Congressman Zinke for his dedication and perseverance to ensuring that our veterans and entire communities will continue to have access to vital ground ambulance service,” said AAA President, Randy Strozyk.
The American Ambulance Association will be presenting Congressman Zinke with his Legislative Recognition Award this November at the AAA Annual Stars of Life Event, which honors emergency medical services professionals from around the nation who have gone above and beyond in service to their communities.
FOR IMMEDIATE RELEASE
Contact:
Tristan North
tnorth@ambulance.org
October 8, 2024
Senator Jerry Moran Honored with Legislative Recognition Award
from the American Ambulance Association
Washington, D.C. — The American Ambulance Association (AAA) has awarded Jerry Moran (KS) a 2024 AAA Legislative Recognition Award in recognition of his leadership in ensuring veterans continue to have access to emergency 9-1-1 and interfacility ground ambulance services.
Senator Moran introduced with a bipartisan group of Senators the VA Emergency Transportation Access Act (S. 2757, H.R. 6433) to direct the Department of Veterans Affairs (VA) to further analyze the impact of the VA Final Rule on Special Modes of Transportation and create an advisory committee to evaluate future reimbursement rates for ambulance services.
The Rule as it stands would reimburse ambulance service providers below the costs of providing medical and transport services. S. 2757 would help ensure that ambulance service providers throughout Kansas and the country do not face further cuts to VA reimbursement which would limit their ability to provide lifesaving emergency medical services to our nation’s veterans.
Due to the efforts of Senator Moran and a bipartisan group of Senators and Representatives, the VA has recently stated it will delay implementation of the Final Rule for four years which would provide time to determine more fair and adequate payment rates for ambulance services.
“We greatly appreciate the leadership of Senator Moran in ensuring that our veterans and entire communities will continue to have access to vital ground ambulance service,” said AAA President, Randy Strozyk. “His perseverance paid off with the VA recognizing the need to delay implementation of the final rule to provide more time to address concerns that the new payment system could adversely affect ambulance access for veterans.”
The American Ambulance Association will be presenting Senator Moran with his Legislative Recognition Award this November at the AAA Annual Stars of Life Event, which honors emergency medical services professionals from around the nation who have gone above and beyond in service to their communities.
FOR IMMEDIATE RELEASE
Contact:
Tristan North
tnorth@ambulance.org
October 7, 2024
Senator Jon Tester Honored with Legislative Recognition Award
from the American Ambulance Association
Washington, D.C. — The American Ambulance Association (AAA) has awarded Senator Jon Tester (MT) a 2024 AAA Legislative Recognition Award in recognition of his leadership in ensuring veterans continue to have access to emergency 9-1-1 and interfacility ground ambulance services.
Senator Tester introduced with a bipartisan group of Senators the VA Emergency Transportation Access Act (S. 2757, H.R. 6433) to direct the Department of Veterans Affairs (VA) to further analyze the impact of the VA Final Rule on Special Modes of Transportation and create an advisory committee to evaluate future reimbursement rates for ambulance services.
The Rule as it stands would reimburse ambulance service providers below the costs of providing medical and transport services. S. 2757 would help ensure that ambulance service providers throughout Montana and the country do not face further cuts to VA reimbursement which would limit their ability to provide lifesaving emergency medical services to our nation’s veterans.
Due to the efforts of Senator Tester and a bipartisan group of Senators and Representatives, the VA has recently stated it will delay implementation of the Final Rule for four years which would provide time to determine more fair and adequate payment rates for ambulance services.
“Senator Tester’s leadership on this issue has been instrumental in advancing our mission to preserve emergency medical services for veterans and entire communities,” said AAA President, Randy Strozyk. “His dedication to supporting our nation’s heroes exemplifies the kind of leadership we need to ensure that all veterans have access to timely and efficient emergency care.”
The American Ambulance Association will be presenting Senator Jon Tester with his Legislative Recognition Award this November at the AAA Annual Stars of Life Event, which honors emergency medical services professionals from around the nation who have gone above and beyond in service to their communitie
Press Contact
Tristan North
Senior Vice President
American Ambulance Association
tnorth@ambulance.org
FOR IMMEDIATE RELEASE
Congresswoman Gluesenkamp Perez Awarded 2024 Legislator of the Year by the American Ambulance Association
Washington, D.C. — September 23, 2024 — Congresswoman Marie Gluesenkamp Perez has been recognized as the 2024 Legislator of the Year by the American Ambulance Association (AAA) for her outstanding leadership in addressing the critical workforce shortage facing the Emergency Medical Services (EMS) industry.
In a time when the EMS sector grapples with a significant shortage of qualified personnel, Congresswoman Gluesenkamp Perez has emerged as a vital advocate for meaningful change. Her introduction of the H.R. 6433, the PARA-EMT Act, has been a pivotal step in advancing solutions to recruit and retain EMS professionals across the nation.
“Congresswoman Gluesenkamp Perez’s commitment to the EMS workforce is not just commendable; it is essential,” said AAA President Randy Strozyk. “Her leadership has laid the groundwork for policies that will help alleviate the workforce crisis, ensuring that our communities receive the emergency care they deserve.”
The PARA-EMT Act aims to create an EMS Workforce Grant to help recruit, train, and retain EMS professionals and tasks the Department of Labor and Department of Health and Human Services with creating a study of the EMS workforce shortage and the training and education needed to meet the demands of the pre-hospital industry over the next decade. Additionally, the legislation includes a provision to assist combat medics with first response experience in transitioning into the civilian workforce.
Introduction of this legislation reflects the Congresswoman’s dedication not only to securing a strong future for emergency medical services to meet the needs of our communities, but also her dedication to serving our nation’s veterans.
The American Ambulance Association is honored to award our Legislator of the Year Award to Congresswoman Marie Gluesenkamp Perez, a true advocate of emergency medical services.
The award will be presented at the AAA Stars of Life event in Washington, D.C. on November 12th.
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The American Ambulance Association represents ambulance services across the United States that participate in serving more than 75% of the U.S. population with emergency and non-emergency care and medical transportation. The AAA was formed in response to the need for improvements in medical transportation and emergency medical services. AAA views pre-hospital care not only as a public service, but also as an essential part of the total public health care system.
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The Department of Veterans Affairs (VA) has notified Senate Committee on Veterans Affairs Chairman Jon Tester (D-MT) and Ranking Member Jerry Moran (R-KS) that the Department will be delaying implementation of the Final Rule on Special Modes of Transportation until February 16, 2029. The Committee has released a statement on the delay and the VA should be issuing a formal notification of the delay shortly in the Federal Register.
“I appreciate the VA providing the additional time to ensure a process for proper reimbursement of critical ambulance services for veterans and wholeheartedly thank Chairman Tester and Ranking Member Moran for their successful and tireless efforts in advocating for the delay,” stated AAA President Randy Strozyk. “Reimbursing ground ambulance services at Medicare rates would have a devasting impact on our members who are already struggling financially.”
The delay will allow time for a framework like the one outlined in the VA Emergency Transportation Access Act (S. 2757, H.R. 5530) to allow stakeholder input on future rates. “Our members appreciate the efforts of Senators Tester, Moran, Patty Murray, John Boozman and Susan Collins and Representatives Mike Bost and Ryan Zinke and the dozens of other members of Congress who helped push for the delay.”
The Final Rule on Special Modes of Transportation was originally scheduled to take effect on February 16, 2024, but in December 2023 the VA announced a one-year delay with the latest announcement delaying implementation for an additional four years. Under the final rule, the VA would reimburse for ambulance services provided through its beneficiary travel program at the lesser of the actual charges or Medicare rates.
We will provide more details about the delay when the VA issues its formal notice.
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