Updated CMS FAQs on the Ambulance Data Collection

Updated CMS FAQs on the Ambulance Data Collection System and Reporting Requirement Delay

As we recently reported, CMS announced that it will be delaying the implementation of the statutorily mandated ambulance data collection system.  CMS has released a new set of Frequently Asked Questions (FAQs) clarifying the delay.  In sum, ambulance organizations selected to provide cost data for 2020 will now be required to report 2021 data in Year 2.  CMS will also add a new set of ambulance organizations for Year 2 reporting as well.  This means that twice as many ambulance organizations will be reporting 2021 data in Year 2 and there will be no data reported for 2020.  Any organization selected that does not report data will be subject to the 10 percent penalty, unless an exception applies.  In addition to addressing concerns about reporting during the pandemic, the FAQs suggest that CMS is concerned that 2020 data “may not be reflective of typical costs and revenue associated with providing ground ambulance services.”

The complete list of these questions, as well as previous ambulance FAQs for COVID-19 on Medicare Fee-for-Service (FFS) Billing can be found here.  The new data collections are below.

Data Collection and Reporting Requirements for the Medicare Ground Ambulance Data Collection System

 1. Question: CMS requires selected ground ambulance organizations to collect cost, revenue, utilization, and other information through the Medicare Ground Ambulance Data Collection System. The collected information will be provided to MedPAC, which is required to submit a report to Congress on the adequacy of Medicare payment rates for ground ambulance services and geographic variations in the cost of furnishing such services. Will the data collection and reporting requirements for the Medicare Ground Ambulance Data Collection System be delayed due to COVID-19?

Answer: Yes. CMS has issued a blanket waiver: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration- waivers.pdf due to the PHE for the COVID-19 pandemic. CMS is modifying the data collection period and data reporting period, as defined at 42 CFR §414.626(a), for ground ambulance organizations that were selected by CMS to collect data beginning between January 1, 2020, and December 31, 2020 (Year 1).

Under this modification, these ground ambulance organizations can select a new data collection period that begins between January 1, 2021, and December 31, 2021; collect the necessary data during their selected data collection period; and submit the data during the data reporting period that corresponds to their selected data collection period.

CMS is modifying this data collection and reporting period to increase flexibilities for ground ambulance organizations that would otherwise be required to collect data in 2020–2021 so that they can focus on their operations in support of patient care.

As a result of this modification, ground ambulance organizations selected for year 1 data collection and reporting will collect and report data during the same period of time that will apply to ground ambulance organizations selected by CMS under §414.626(c) to collect data beginning between January 1, 2021, and December 31, 2021 (year 2) for purposes of complying with the data reporting requirements described at §414.626.

For additional information on the Medicare Ground Ambulance Data Collection System, please visit the Ambulances Services Center website at

https://www.cms.gov/Center/Provider-Type/Ambulances-Services-Center.

New: 6/16/20

2. Question: Will the 10 percent payment reduction still apply to ground ambulance organizations that are now required to collect and report data under the modified data collection and reporting period but do not sufficiently report the required data?

Answer: Yes. The 10 percent payment reduction described at 42 CFR §414.610(c)(9) will still apply if a ground ambulance organization is selected to collect and report data under the modified data collection and reporting timeframe, but does not sufficiently submit the required data according to the modified timeframe and is not granted a hardship exemption. The payment reduction will be applied to payments made under the Medicare Part B Ambulance Fee Schedule for services furnished during the calendar year that begins following the date that CMS provides written notification that the ground ambulance organization did not submit the required data.

New: 6/16/20

3. Question: The modification states that the ground ambulance organizations that were selected by CMS to collect data beginning between January 1, 2020, and December 31, 2020 (year 1) can select a new continuous 12-month data collection period that begins between January 1, 2021, and December 31, 2021. Do the ground ambulance organizations that were selected in year 1 have an option to continue with their current data collection period that started in early 2020 or choose to select a new data collection period starting in 2021?

Answer: No. The ground ambulance organizations that were selected for year 1 do not have an option and must select a new data collection period that begins in 2021. CMS cannot permit this option because the data collected in 2020 during the PHE may not be reflective of typical costs and revenue associated with providing ground ambulance services. New: 6/16/20

4. Question: Does the guidance mean that there will be no data reporting in 2021 and that both the ground ambulance organizations that were selected for year 1 and the ground ambulance organizations that will be selected for year 2 will collect and report data during the same time periods?

Answer: Yes. Under the modification, ground ambulance organizations that are selected for year 1 will not collect data in 2020. These ground ambulance organizations will select a new data collection period that begins in 2021 and must submit a completed Medicare Ground Ambulance Data Collection Instrument during the data reporting period that corresponds to their selected data collection period. As a result of the modification, year 1 and year 2 selected ground ambulance organizations will collect and report data during the same time periods. New: 6/16/20

Savvik Cost Collection Grant Application

The Savvik Foundation and the American Ambulance Association have launched a grant program available to Savvik member ambulance services that are preparing to comply with the Cost Data Collection program through the Centers for Medicare and Medicaid Services. Through Savvik Member purchases under contracts, the Savvik Foundation was able to fund grant dollars through the American Ambulance Association (AAA). Through this grant, services will be eligible to receive a one-year AAA Ambulance Cost Education Gold subscription, which includes access to experts on cost collection, access to AMBER software, and free registration to Webinars and Regional Workshops. To apply, complete the application form below.

Savvik Cost Collection Grant Request

  • Was your organization (at least one NPI) selected by CMS for 2020 cost collection? Only organizations selected for 2020 reporting are eligible to apply for the grant.
  • How many total ambulance transports does your organization conduct annually?
  • How many total ambulance transports does your organization conduct annually IN RURAL and SUPER-RURAL areas?
  • How many registered ambulances does your organization have? Include registered ambulances held as reserve vehicles.
  • Is your organization a current American Ambulance Association member?
  • Is your organization a current Savvik member?
  • Max one paragraph
  • This field is for validation purposes and should be left unchanged.

Cost Data Collection: So You’ve Been Selected—Now What?

It’s finally here! For almost a decade the American Ambulance Association has been preparing for this moment: collecting cost data in order to justify the reimbursement inadequacies of our current payment system. As Benjamin Franklin stated, “By failing to prepare, you are preparing to fail.” So prepare we did! Our research indicated that due to…

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Summary of Final Rule on Ambulance Data Cost Collection

Summary of Final Rule on Ambulance Data Cost Collection The American Ambulance Association (AAA) has completed its review and summary of the Final Rule on the Establishment of an Ambulance Data Collection System drafted by Kathy Lester, Esq. To access the summary of the Final Rule, please click here. The Final Rule is scheduled to be published…

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CMS Posts Final Ambulance Data Collection Instrument

CMS Posts Final Ambulance Data Collection Instrument

The Centers for Medicare & Medicaid Services (CMS) has posted the final version of the Medicare Ground Ambulance Data Collection Instrument. The Instrument is the guidance and mechanism by which CMS will request data from those ambulance service suppliers and providers selected in year one of the sampling.

The posting of the final version of the Instrument follows the release on November 1 of the final rule on the development of an ambulance data collection system and subsequent release on November 2 of the list of the ambulance service suppliers and providers selected in year one to provide their data. To access the list by NPI number click here and to access the list by state click here.

The AAA will keep you posted of new developments with the implementation of the data collection system as well as educational opportunities.

Provider List by NPI

Provider List by State

CMS Releases List of Ambulance Organizations Selected for Data Collection

CMS Releases List of Ambulance Organizations Selected for Data Collection

The Centers for Medicare & Medicaid Services (CMS) has released the list of ambulance service providers and suppliers selected to provide data in the first year of data collection. CMS has published the data by National Provider Identifier (NPI) number and the AAA has also sorted the data by state in alphabetical order.

On Friday, CMS had made public the final rule on the Establishment of an Ambulance Data Collection System. The AAA will be issuing a Member Advisory tomorrow on the details of the final rule and changes from the proposed rule.

To access the list by NPI number click here and to access the list by state click here.

Provider List by NPI

Provider List by State

CMS Releases Final Rule on Ambulance Data Collection System

Late this afternoon, the Centers for Medicare & Medicaid Services (CMS) released the final rule on the “Establishment of an Ambulance Data Collection System”. The rule was issued as part of the “Medicare Program; CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies” [CMS-1715-F and IFC]. The final rule is scheduled for official publication in the November 15 issue of the Federal Register.

The AAA is currently reviewing the final rule to determine changes on the ambulance data collection system from the policies as outlined in the proposed rule of August 15. The proposed rule set forth a system utilizing a survey tool and sampling of ambulance service providers and suppliers as directed by Congress and supported by the AAA. The AAA did, however, submit comments with suggestions as how to fine-tune the process and tool. The AAA also submitted a second letter on the section of the proposal rule making changes related to the physician certification statement (PCS).

We will be issuing a follow up Member Advisory next week with the specific final policy changes on the ambulance data collection system and PCS outlined in the final rule.

CMS Open Door Forum & Member Q&A – November 7th

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, November 7 from 2:00-3:30 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call.

CMS Ambulance Open Door Forum

November 7 | 2:00 PM ET
Participant Dial-In Number:  1-888-455-1397
Conference ID #: 4676500

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.

AAA Follow Up Q&A

November 7 | 4:00 PM ET
1-800-250-2600
Pin: 82802314#
Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.

Submit Comments on Ambulance Data Collection System

Yesterday, the AAA submitted our comment letter to the proposed rule on changes for FY2020 to the Medicare ambulance fee schedule. The comment letter focused on the section of the proposed rule on the ambulance data collection system. For a copy of the detailed 28-page comment letter, please click here.

Read the AAA Comment Letter

The AAA is very pleased with the approach CMS is taking on data collection which is consistent with the intent of the Congress and the methodology developed and advocated by the AAA. While the AAA comment letter is extremely detailed, our only concern is CMS was not able to test or pilot the sampling methodology and data collection instrument prior to inclusion in the proposed rule. Testing would have allowed CMS to fine-tune the survey and may impact the quality of the first year of data.

Now, it is important that AAA members submit their own letters to demonstrate support for the AAA letter and its key points.

AAA members should go to www.regulations.gov and make three points as follows:

  • Our organization supports the approach CMS is proposing to collect ambulance data and we thank CMS and its contractors.
  • Since CMS was unable to test the sampling methodology and data collection tool, we are concerned about the potential quality of the first year of data. We therefore ask CMS to begin education of ambulance service suppliers and providers and work with the American Ambulance Association to adjust the methodology and tool, if necessary, for future data collections.
  • We fully support the specific comments submitted by the American Ambulance Association as to recommended improvements to the data collection tool.

All you need to do is click on www.regulations.gov and include the above three points. Add your first and last name and click “continue” to then finalize your submission.

The AAA has also developed a sample comment letter you can access by clicking here. Go to www.regulations.gov and instead of adding the three points in the comment back, upload your letter.  Please draft your own customized letter using the letter provided by the AAA as a guideline.

Sample Comment Letter

Comments are due by 5:00 pm on Friday, September 27, so please submit your comment letter today! Please also feel free to forward this email to state ambulance associations and other ambulance service organizations.

The AAA will be submitting a second letter in the next week just on seeking clarification around changes to PCS requirements in the proposed rule but will not be asking members to submit similar comments.

We greatly appreciate the work of CMS and its contractors in developing the ambulance data collection system.

Thank you in advance to all of you who take the time to submit comment letters.

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

CMS Open Door Forum & Member Q&A – August 28

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Wednesday, August 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 August 28 | 2:00 PM ET Participant Dial-In Number:  1-888-455-1397 Conference ID #: 6609831 Questions?…

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Ambulance Cost Collection Rule Summary

The proposed rule sets the foundation for the data collection system for ground ambulances.  It proposes a stratified random sample method, that is very similar to the one the AAA proposed via the work we commissioned through The Moran Company. We are working through the stratification categories, which are slightly different than those we identified. CMS…

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CMS Releases Proposed Cost Collection Rule

Today, CMS has released the proposed rule that would establish the ambulance fee schedule cost collection system as required by statute. The AAA is currently reviewing the rule and will provide a more detailed summary in the coming days.

On Tueusday, July 30 at 12:00pm Eastern, the AAA will be hosting a free webinar during which AAA counsel will provide an overview of the proposals in the rule. Do not miss out on this chance for the most up to date information.

Read the Proposed Rule

Sign Up for the Webinar

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

AAA Webinar Wednesday, March 6: Tools for Billing Services and Other Vendors

Whether you contract with a third-party billing service, or have an internal billing department, the upcoming Ambulance Cost Data Collection (ACE) webinar hosted by the AAA on Wednesday, March 6 is a can’t miss.

As we get closer to new Cost Data Collection requirements taking effect across the ambulance service community, the American Ambulance Association has been developing Ambulance Cost Education tools and information to make it easier for services of all sizes and types to report. Billing services and vendors are a key component of the Cost Data Collection process, and if you have not already involved your contracted servicers or employees, this is a great time to start.

Tools for Billing Services and Other Vendors, presented by Ambulance Cost Education faculty member Aaron Director, will discuss the web-based reporting tool being developed, and share some ideas for vendors to create an integrated, seamless tool through partnership with the AAA. This is the ideal webinar for vendors that serve the ambulance community, and we encourage you to reach out and share this information broadly.  Invite them to participate and get involved!

We know things go better when we work together, and that is why the AAA is working so hard to make sure the Cost Data Collection process is inclusive. These webinars are available as part of a subscription package or On Demand. To learn more about Ambulance Cost Data Collection and all the American Ambulance Association is doing to help services across the country prepare, visit www.ambulancereports.org.  You will find both free resources and paid subscriptions are available to fit your budget and help your service prepare for the future of EMS.

 

 

Request for Proposals—SME/Project Director

American Ambulance Association Request for Proposals SME/ Project Director Ambulance Cost Data Collection November 2018 Overview The American Ambulance Association (AAA) invites proposals from qualified interested parties (individual and teams) for the purpose of directing the Ambulance Cost Data Project as a Subject Matter Expert (SME). Introduction As part of the extension of the Ambulance…

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Cost Data Collection Quick Take: NPIs

As part of AAA’s Cost Data Collection Quick Takes series, here’s a brief discussion about the issues around having single or multiple NPIs under the new data collection requirements. Sign-up for our Cost Data Collection email list for important updates on webinars, tools, and resources….

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Statement on Ambulance Cost Data Collection

October 22, 2018

Contact: Amanda Riordan
Phone: 703-615-4492
Email: ariordan@ambulance.org

For Immediate Release

Statement on Cost Data Collection for Ambulance Services

WASHINGTON, DC—On October 17, the International Association of Fire Chiefs (IAFC), International Association of Fire Fighters (IAFF), and The Metropolitan Fire Chiefs Association released a joint statement discouraging fire-based providers from endorsing AAA’s proposed ambulance cost collection methodology. While we regret to learn that they do not believe that our method is appropriate for the segment of providers they represent, we respectfully disagree and invite open dialogue as our previous requests to discuss cost collection with the IAFF and IAFC were declined.

The American Ambulance Association membership is composed of ambulance providers of all types and sizes, ranging from non-profit, for-profit, volunteer, hospital-based, county-based, public utility models, and more. We represent 911 ambulance providers in major metropolitan areas, small 911 providers in rural America, and those who provide vital hospital-to-hospital interfacility mobile healthcare throughout the country. AAA encourages all ambulance providers to visit www.ambulancereports.org to learn about the extensive research, time, and thought devoted to ensure that our comprehensive recommendations accurately capture data for the full spectrum of providers.

“Regardless of an ambulance organization’s service model, we collectively serve our communities with round-the-clock mobile healthcare. The collection and analysis of accurate cost data for ambulance providers of all types is essential to the future of our industry. If adopted by CMS, AAA’s cost collection recommendations will demonstrate the value of the care that we provide to our patients, as well as open the door for the establishment of forward-thinking payment models that sustain operations and grow innovation. The American Ambulance Association welcomes discussion with fire and other stakeholders. Our door is always open,” said AAA President Aarron Reinert on Monday.

Medicare cost reporting is an exhaustive and extremely technical system that has been in place in other healthcare specialties for many years. While not all ambulance services are Medicare “providers of service,” it has long been clear to AAA that ambulance services would eventually be required to provide cost data to support Medicare reimbursement, especially for purposes of making the add-ons permanent and expanding the benefit to include innovative payment models, including mobile integrated health. As such, our ambulance cost collection leadership began in 2012 with the commission of an extensive independent research study to design a cost model that would be accurate, complete, and minimally burdensome to ambulance providers of all sizes, types, and models. The findings of this study were released in 2014 and form the foundation of AAA’s cost data collection system design.

Following extensive advocacy efforts led by the American Ambulance Association, the Bipartisan Budget Act of 2018 was passed into law in February of this year. This bill included language that extended the ambulance Medicare add-ons for five years. It also required that ambulance services begin collecting and reporting cost data to the Centers for Medicare & Medicaid Services (CMS) in 2020. CMS has the ability to determine certain aspects of how the data is collected as well as the data elements so AAA is working closely with this agency to advocate for the implementation of our survey-based model. It is also clear that given the Congressional instruction to use the cost collection data to assess Medicare rates, the data collection will be aligned with the costs Medicare has the statutory authority to reimburse, but not necessarily all costs suppliers may incur to support the non-healthcare aspects of their services.

It is essential that ambulance providers speak with one voice on this critically important issue.  Inconsistencies in reporting and failure to standardize costs allowable under the Medicare statute will result in data being eliminated and will threaten the sustainability of the program. As such, throughout this lengthy and intensive process, AAA leadership remains open to feedback and focused on the development of and advocacy for a cost collection system that encompasses all mobile healthcare provider types. Learn more at www.ambulancereports.org.

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About the American Ambulance Association (AAA)

The AAA was formed in 1979 in response to the need for improvements in emergency medical services and mobile healthcare. The American Ambulance Association represents hundreds of ambulance services across the United States who provide emergency and interfacility mobile healthcare. The Association serves as a voice and clearinghouse for ambulance services.

CMS Launches Outreach Effort to Ambulance Providers & Suppliers

As part of the Bipartisan Budget Act of 2018 (BBA 2018), the Congress instructed CMS to develop a cost collection system to collect cost and revenue data related to the provision of ambulance services. Ambulance services are defined by federal law to include all levels of emergency and non-emergency services. 

CMS is in the first phase of this process. The Congress instructed the Agency to engage with stakeholders before specifying through notice and comment rulemaking the data collection system. By law, CMS is required to specify the final system by December 31, 2019. CMS must also identify the first group of providers and suppliers selected for the first representative sample by that date as well. It appears that the goal is to have the contractor develop a proposal before the 2019 rulemaking cycle which will begin next summer.

To engage with the stakeholders, CMS, through its contractor the RAND Corporation, is reaching out providers and suppliers to learn more about the costs and revenues associated with providing ambulance services.

During the American Ambulance Association’s annual meeting earlier this month, CMS through the RAND Corporation, convened a focus group where they selected several AAA members who were able to talk directly with the contractor. The discussion centered around characteristics of ambulance services that matter for determining costs. The group also talked about how data is currently captured at the state and local levels, as well as how data is tracked within ambulance services. There was also a lot of discussion about the importance of standardizing data elements and not relying upon different state or local definitions, which could confound the data and make it impossible to compare costs across states.

As we have reported previously, it is critically important that the data collected through this process is standardized and reflects the actual cost of providing ambulance services. It is important to make sure that the data is useable not only for supporting the ambulance add-ons after they next expire in 2023, but also to help implement broader reforms and innovative payment models.

CMS is now reaching out to others in the industry. If you receive an email or a phone call from RAND Corporation, please respond. 

If you have questions about, or would like assistance with regard to, this project, please contact Tristan North at tnorth@ambulance.org.

NEW! AAA PreCon Workshop on Mandatory Cost Data Collection

AAA is excited to announce that this year we will be holding a full day pre-conference workshop at the AAA Annual Conference & Trade Show! Join industry experts Rebecca Williamson, Angie McLain, Asbel Montes, Kathy Lester, Scott Moore, and Brian Werfel to learn what the new cost data collection mandates will require and how you and your service can get ahead of the game and prepare for these changes.

Mandatory Cost Data Collection: When Is It Happening & How to Prepare

September 5, 2018 | 9:00 AM – 4:00 PM | MGM Grand, Las Vegas
$75 for Annual Conference attendees | $250 workshop-only

2018 federal legislation expanded Medicare cost reporting to ambulance services, although with some important differences from other Medicare reporters. Failure to meet these new reporting requirements could lead to significant sanctions including loss of Medicare revenue. In this session, we will review how we got to where we are, what the new mandates will require based on current regulations, and how best to prepare yourself and your service for the phase-in.

Physician Fee Schedule Proposed Rule 2018

On Thursday, July 12, the Centers for Medicare & Medicaid Services (CMS) released the “Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program” Proposed Rule (Proposed Rule). As you know, the American Ambulance…

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