Congress Extends Ambulance Add-On Payments Through September 30
Yesterday evening, March 14, the United States Senate by a vote of 54 to 46 passed the Full-Year Continuining Appropriations and Extensions Act, 2025 (H.R. 1968) to fund the federal government through the end of the 2025 fiscal year ending September 30. An extension of the current levels of the temporary Medicare ambulance add-on payments was included in H.R. 1968 with an expiration date of also September 30. President Trump is expected to sign H.R. 1968 into law shortly.
The AAA, our champions and supporters on Capitol Hill, and EMS partner organizations fought hard to ensure the ambulance extension was included in the lean bill of just 99 pages. We greatly appreciate the outreach by the AAA membership and state EMS associations to their members of Congress in support of the extension of the ambulance add-on payments. The AAA will continue to advocate for a long-term extension of the add-on payments at the higher levels of 3.4% urban, 4.3% rural and 26.7% super rural.
Revised versions of the Protecting Access to Ground Ambulance Medical Services Act with a long-term extension of the add-on payments, and at the higher levels in the Senate bill, will be reintroduced in the near future. Once introduced, we will be launching a new Call To Action asking you to contact your members of Congress to cosponsor the legislation
President Jamie Pafford-Gresham on the Ambulance Medicare Extenders
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or31 State Ambulance Associations Request Support of EMS Supplemental Payments
March 7, 2025
The Honorable Brett Guthrie
Chair
Committee on Energy and Commerce
United States House of Representatives
2161 Rayburn House Office Building
Washington, DC 20515
The Honorable Buddy Carter
Chair
Energy and Commerce Subcommittee on Health
United States House of Representatives
2432 Rayburn House Office Building
Washington, DC 20515
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
United States House of Representatives
2107 Rayburn House Office Building
Washington, DC 20515
The Honorable Dianna DeGette
Ranking Member
Energy and Commerce Subcommittee on
Health
United States House of Representatives
2111 Rayburn House Office Building
Washington, DC 20515
Re: Medicaid Supplemental Payments for Ground Ambulance Services
Dear Chair Guthrie, Ranking Member Pallone, Chair Carter, and Ranking Member DeGette,
On behalf of 31 state ambulance and emergency medical services (EMS) associations, we ask for your continued support for Medicaid supplemental payment programs that provide critical support to EMS providers.
Ambulance service providers face financial pressures and risk closure at an alarming rate in every state. In rural communities in particular, EMS providers are often the only healthcare providers delivering care for hundreds of miles. Medicaid supplemental payment programs offer transparent and sustainable ways to support first responders, allowing them to continue providing life-saving services, train paramedics, and ensure our rural communities are not left without care.
The most at-risk ambulance service providers—those serving rural communities—face unique challenges including large coverage areas, increased travel distances, and higher costs per transport. Adequate support for staffing, training, and equipment is already a major challenge. Medicaid supplemental payment programs focus on improving rural access to care by driving dedicated resources to those communities.
We are deeply concerned by recent proposals that would severely reduce critical Medicaid reimbursement by reducing provider assessments and mandating the use of artificial caps on supplemental payments that would prevent rates from covering costs.
EMS and ambulance service providers, rural hospitals, and safety-net health clinics will close without continued funding that Medicaid supplemental payment funds provide.
Our ambulance associations are eager to collaborate with the Congress and the Administration on solutions that sustain Medicaid financing and ensure ambulance service providers continue to meet the needs of their communities. We appreciate the opportunity to engage in further discussion and provide data on how these programs directly affect each of our states.
Sincerely,
Alabama Association of Ambulance Services
Arkansas Ambulance Association
California Ambulance Association
EMS Association of Colorado
Georgia Ambulance Providers Association
Kentucky Ambulance Providers Association
Louisiana Ambulance Alliance
Massachusetts Ambulance Association
Michigan Association of Ambulance Services
Minnesota Ambulance Association
Mississippi Ambulance Alliance
Missouri Ambulance Association
Montana Ambulance Association
Nevada Ambulance Association
New Hampshire Ambulance Association
Medical Transportation Association of New Jersey
United New York Ambulance Network
Ohio Ambulance & Medical Transportation Association
Oklahoma Ambulance Association
Oregon State Ambulance Association
Ambulance Association of Pennsylvania
South Carolina EMS Association
Tennessee Ambulance Service Association
Texas Ambulance Association
Texas EMS Alliance
Vermont Ambulance Association
Virginia Ambulance Association
Washington Ambulance Association
West Virginia EMS Coalition
Professional Ambulance Association of Wisconsin
Wyoming EMS Association
MedPAC Commissioners Recognize Importance of Ground Ambulance Services and Complexities of AFS
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or2025 Medicare Reference Manual Released
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CFPB Finalizes Rule Prohibiting Inclusion of Medical Debt on Credit Reports
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orAAA Releases 2025 Medicare Rate Calculator
On 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).
2025 Medicaid Rate Survey Released
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:
- A0428 – BLS Non-Emergency
- A0429 – BLS Emergency
- A0426 – ALS Non-Emergency
- A0427 – ALS Emergency
- A0433 – ALS-2
- A0434 – SCT
- A0225 – Neonate Transport
- A0998 – Treatment, No Transport
- A0425 – Mileage
- A0422 – Oxygen
- A0382/A0398 – BLS/ALS Routine Disposable Supplies
- A0420 – Wait Time
- A0424 – Extra Attendant
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.
Whitepaper | State-Level Ambulance Balance Billing Overview
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.)
CMS Posts Revised 2025 Public Use File
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orA Message from AAA President Jamie Pafford-Gresham
Happy New Year from Our New Association President
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Congress Extends Medicare Ambulance Add-On Payments
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.
GADCS Year 1 & Year 2 Cohort Analysis Released
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orHHS OIG Issues Favorable Advisory Opinion on Ambulance Treatment-in-Place
On 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).
Manchin and Collins Introduce Senate TIP Bill
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orCMS Finalizes the Productivity Adjustment, Adds Prehospital Blood Transfusion to ALS2
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orSenator Stabenow Receives Inaugural EMS Legacy Award
FOR IMMEDIATE RELEASE
Contact:
Tristan North
tnorth@ambulance.org
October 10, 2024
Senator Debbie Stabenow Receives Inaugural EMS Legacy Award from the American Ambulance Association
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.
CMS Announces CY 2025 Ambulance Inflation Factor
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