House Energy & Commerce Subcommittee Takes Action on Balance Billing

On July 11, 2019, the House Energy and Commerce Committee Health Subcommittee held a markup in which they advanced 10 health care bills, including legislation on surprise/balance billing. This legislation, H.R. 3630, the No Surprises Act attempts to address out-of-network surprise medical bills. The AAA Government Affairs team has been in regular communication with the Energy and Commerce Committee and member offices leading up to the markup to ensure that the ground ambulance industry and AAA members were not negatively impacted by the legislation or any introduced amendments. Thanks to the attentive efforts of AAA members, staff, and consultants, there was no mention of ground ambulance during the markup of H.R. 3630, the No Surprises Act. While ground ambulance was not mentioned, Rep. Lujan (D-NM) highlighted the air ambulance transparency language that is included in the No Surprises Act and called for it to be strengthened further before this legislation is considered by the full Energy and Commerce Committee. Over the course of the markup, Subcommittee Chairwoman Eshoo (D-CA) thanked Rep. Lujan for bringing attention to the “extraordinary costs” associated with air ambulance. Rep. Ruiz (D-CA) then expressed his ongoing concerns regarding the balance billing provisions of the No Surprises...

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CMMI Releases Preview of ET3 RFA

On May 22, 2019, the Center for Medicare and Medicaid Innovation (CMMI) released a preview of the Request for Applications (RFAs). This documentation will be used by ambulance providers and suppliers to apply for inclusion as “Participants” in the Emergency Triage, Treat, and Transport (ET3) pilot program. Webinar: Learn More About the RFA June 13, 2019 | 2:00 PM Eastern Speakers: Brian Werfel, Kathy Lester, Rebecca Williamson, Asbel Montes $99 for Members | $198 for Non-Members Relevant Background On February 14, 2019, CMMI announced the creation of a new 5-year pilot program designed to give participating EMS agencies greater flexibility to address the needs of Medicare beneficiaries following a 911 call. The ET3 model would create a new payment model under which participating EMS agencies will be eligible for Medicare reimbursement for: (1) transportation to alternative treatment destinations and (2) treatment at the scene. At the time, CMMI indicated that it anticipated starting the ET3 model in early 2020. To that end, CMMI anticipated soliciting Requests for Participation in the Summer of 2019. Participation in this pilot program is voluntary. Regardless of whether an ambulance provider or supplier participates in the pilot program, payment for ambulance transportation currently covered under...

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CMS Releases ET3 Request for Applications (RFA)

Just minutes ago, the Centers for Medicare & Medicaid Services (CMS) announced the release of the Request for Applications (RFA) for the Emergency Triage, Treat, and Transport (ET3) Model. The RFA can be found here. CMS is not accepting applications at this time but has released the RFA so that those ambulance services thinking about submitting an application can review it. In the notice, CMS also shared some FAQs on ET3. The AAA team is currently reviewing the RFA and will be sending out a notice with additional details shortly.

New SNF PPS Edits Highlight the Importance of Facility Agreements

On April 1, 2019, CMS implemented a new series of Common Working File (CWF) edits that are intended to better identify ground ambulance transports that are furnished in connection with an outpatient hospital service that is properly bundled to the skilled nursing facility (SNF) under the SNF Consolidated Billing regime. These edits work by comparing the ambulance claim to the associated outpatient hospital claim.  Hospital claims were already subject to CWF edits designed to identify outpatient hospital services that should be bundled to the SNF.  These hospital edits operate by referencing a list of Healthcare Common Procedure Coding System (HCPCS) or Current Procedural Terminology (CPT) codes that correspond to outpatient hospital services that are expressly excluded from SNF Consolidated Billing.  Hospital claims for outpatient services that are submitted with one of these excluded codes bypass the existing CWF edits, and are then sent to the appropriate Medicare Administrative Contractor for further editing and payment.  Hospital claims submitted without one of these codes are denied for SNF Consolidated Billing. The new ambulance edits will extend these process one step further.  The ambulance claim will be associated with the outpatient hospital claim on the same date.  To the extent that hospital claim...

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Member Update on Balance Billing

This morning Ruth Hazdovac and Aidan Camas of AAA staff and Kathy Lester, Esq, Healthcare Consultant to the AAA attended a briefing held by the House Energy & Commerce Committee on the issue of surprise/balance billing. At the briefing, staff for Chairman Frank Pallone (D-NJ) and Ranking Member Greg Walden (R-OR) announced that they would be releasing a bipartisan discussion draft, the No Surprises Act, which would “protect consumers from surprise medical bills and increase transparency in our health care system.” As of now, ground and air ambulances are NOT included in the discussion draft. However, the committee is asking for comments on ground and air ambulance and recommendations on how to provide relief to the consumer in this area. The AAA has a Balance Billing Work Group that is hard at work developing a policy recommendation that will work for our members. The House Ways and Means Health Subcommittee Chairman Lloyd Doggett also announced today that the Health Subcommittee will hold a hearing next week entitled “Hearing on Protecting Patients from Surprise Medical Bills.” AAA Staff will be at the briefing and provide a timely update to membership on any developments. The AAA team will be submitting comments and (more…)

Summary of March 28, 2019 Ambulance ODF

The Centers for Medicare and Medicaid Services (CMS) held its latest Open Door Forum on Wednesday, March 28, 2019.  As with past Open Door Forums, CMS started the call with the following announcements: Ambulance Cost Data Collection – CMS reminded the industry that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, requires CMS to create a new cost data collection system by December 31, 2019. Emergency Triage, Treat, and Transport Model – A representative from the Innovation Center within CMS provided an overview of the “Emergency Triage, Treat, and Transport Model” or “ET3.” This is a 5-year pilot program intended to provide ambulance providers with greater flexibility to handle low-acuity 911 calls, by providing Medicare payment for: (a) ambulance transportation to alternative treatment destinations and (b) treatment at the scene. The CMS representative indicated that CMS is in possession of data that suggests that 16% of emergency ambulance transports to a hospital emergency department could have been resolved by transporting the patient to an alternative treatment site, e.g., an urgent care center. CMS estimates that had all of these patients elected to receive care in the lower-acuity setting, it would have saved the Medicare Program approximately $560 (more…)

UPDATED: CMS Open Door Forum – Thursday, March 28

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, March 28 at 2:00 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call. CMS Ambulance Open Door Forum March 28 | 2:00 PM ET Participant Dial-In Number:  1-800-837-1935 Conference ID #: 6695896 Questions? Have more questions? The AAA is here to help! Following the ODF the AAA will be publishing a follow up blog post going over any updates and important announcements.

Update on New SNF Edits

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing. In a Member Advisory issued last week, the AAA provided an update on a series of new Common Working File (CWF) edits intended to identify ambulance transports furnished in connection with outpatient hospital services that are properly bundled to the skilled nursing facility under the SNF Consolidated Billing regime. These new edits are set to go into effect on April 1, 2019.  In our discussion of the implementation specifics, we attempted to answer the question of what would happen when an ambulance claim is submitted prior to the receipt of the associated hospital outpatient claim, and where the associated hospital claim eventually hit Medicare’s system. Specifically, we indicated as follows: “The Transmittal contains further instructions that the CWF be updated to identify previously rejected ambulance claims upon receipt of an associated hospital claim for the same date of service that contains an Exempted Code.  Once identified, the Shared System Maintainer (SSM) is supposed to adjust the previously rejected or denied ambulance claim.  At this point, the nature of that “adjustment” is...

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