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ACE Cost Data Collection Newsletter | May 2024

Submit Your GACDS Data By May 31, 2024

Ground Ambulance Organizations with an NPI identified in the Year 3 and Year 4 CMS GADCS selection lists are expected to submit their data to CMS in 2024. Agencies are expected to submit their data 5 months after the close of their data collection period. For most organizations the data collection period was January 1, 2023-December 31, 2023 with a submission deadline of May 31, 2024.

The GADCS Frequently Asked Questions (FAQ) document contains several examples of data collection periods and submission deadlines. If your organization has an NPI identified in the Year 3 or Year 4 selection list and you have not yet submitted your initial information, you are required to do so via the Palmetto GBA website immediately.

CMS provided a walkthrough of the GADCS system. This video is approximately 2.5 hours long.

5 Tips for Submitting On Time and Avoiding Penalties

  1. Verify your organizations selection year via the lists available on the CMS GADCS website and determine your timeline for collection and submission.
    • If you have not submitted your initial information to CMS, do so immediately via this Palmetto GBA website.
  2. Request access to the CMS GADCS portal so you can submit your data on time and avoid penalty! (This process can take time, do not wait until the last minute!)
    • CMS requires 2 user roles: submitter & certifier. Follow the steps outlined in the CMS GADCS User Guide for successful setup and submission.
  3. Login or request FREE access to Amber, the cost collection tool for EMS & Fire. This web-based tool will help you collect, organize, and verify your data prior to submitting it to CMS.
    • Amber allows organizations to retain a copy of the data submitted
    • Amber provides a PDF export to assist with CMS submission
  4. Engage with your team members. This is bigger than billing and you will need to engage several departments and team members to gather all required cost and revenue information.
  5. If you get stuck, ask for help! Our Cost Collection Experts are on standby, ready to assist you. Email hello@ambulance.org with your question for assistance.
This 20-minute video walks through the updated features and flow of Amber: The Cost Collection Tool for EMS & Fire.
The American Ambulance Association (AAA) has learned that the Centers for Medicare and Medicaid Services (CMS) has started to send notices to ground ambulance providers that missed their deadline to submit cost data under the Medicare Ground Ambulance Data Collection System (GADCS).  The notice indicates that these providers will be subject to a 10% reduction in their Medicare payments for a full calendar year unless they take certain remedial steps.  The good news is that CMS is offering providers that failed to submit their cost data in a timely manner a grace period in which to submit this information and avoid the future payment reduction.

Read the full member advisory on the AAA website.

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CMS Ambulance Open Door Forum: Rescheduled

The Ambulance Open Door Forum has been rescheduled from March 14th to NEW DATE date, April 11th at the same time of 2:00pm-3:00pm ET. Thank you.

Register Here

Overview:

The Ambulance Open Door Forum (ODF) addresses issues related to the Medicare payment, billing, and coverage for air and ground ambulance services. The Ambulance Fee Schedule (AFS) proposed and final rules, rural and other additional payments under the AFS, and Prior Authorization of Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) are just some of the many types of issues addressed within the forum. In addition, discussions differentiating the rules related to ambulance providers and independent ambulance suppliers are facilitated. Timely announcements and clarifications regarding important rulemaking, agency program initiatives and other related areas are also included in the forum.

CMS Releases New GADCS Tip Sheet for Rural, Super Rural Services

The Centers for Medicare & Medicaid Services (CMS) released a new “Reporting for Rural and Super-Rural Organizations Tip Sheet” on February 16, 2024. This guide assists ground ambulance organizations in rural and super-rural areas to meet the Medicare Ground Ambulance Data Collection System (GADCS) requirements.

You can find all of their tip sheets, including those focused on allocation, governmental, and public safety organizations, on the CMS GADCS website.

Services selected as part of the Year 3 and Year 4 list are due to submit their 2023 data to CMS by May 31, 2024, or 5 months after the close of their fiscal year. The AAA offers various resources to help services collect, verify, and submit data on time and avoid penalties. For more information about our resources, including Amber, email hello@ambulance.org.

CMS Updates GADCS User Guide | Feb 29 Office Hours

CMS header
Dear Ground Ambulance Providers and Suppliers,

Starting January 1, 2024, selected ground ambulance organizations in Year 3 and Year 4 are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10 percent payment reduction.

Learn about an updated user guide and upcoming webinar:

Medicare Ground Ambulance Data Collection System: Updated GADCS User Guide

CMS updated the step-by-step Medicare Ground Ambulance Data Collection System (GADCS) User Guide to include changes that we finalized in the CY 2024 Physician Fee Schedule final rule.

More Information:

 

Medicare Ground Ambulance Data Collection System: Office Hours Session – February 29

Thursday, February 29 from 2–3pm ET

Register for this webinar:

Do you have questions about the Medicare Ground Ambulance Data Collection System (GADCS)? CMS and our contractors will address GADCS-related questions in real-time. While everyone is welcome to participate, this session will be most relevant to selected ground ambulance organizations in Year 3 and Year 4 of the GADCS as they begin reporting data to CMS in 2024.

This session will be divided into 2 topics:

  • 2–2:30pm: GADCS instructions and how to respond to specific questions
  • 2:30–3pm: User accounts, accessing the GADCS portal, and information technology issues

Visit  Medicare Ground Ambulance Data Collection System for resources including:

  • Printable version of the GADCS instrument in English and Spanish
  • Updated GADCS User Guide
  • Tip sheets on reporting and getting access to the GADCS, FAQs, and prior educational sessions
  • Lists of ground ambulance organizations required to participate in Years 1–4

Medicare Ground Ambulance Data Collection System Overview Webinar – January 18

CMS header

Dear ground ambulance providers and suppliers,

Starting January 1, 2024, selected ground ambulance organizations in Year 3 and Year 4 are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10 percent payment reduction.

Medicare Ground Ambulance Data Collection System Overview Webinar – January 18

Thursday, January 18 from 2– 3:30 pm ET

Register for this webinar. While everyone is welcome to participate, this session will be most relevant to selected ground ambulance organizations in Years 3 and 4 as they start reporting Medicare Ground Ambulance Data Collection System (GADCS) data to CMS in 2024.

This 60-minute presentation will cover all aspects of the GADCS, including:

  • Overview and key concepts
  • Section walkthrough
  • User accounts, logging in, and linking to your organization
  • Submitting and certifying your data

A Q&A session will follow the presentation.

More Information:

  • Ambulance Events webpage: The January 18 presentation will be posted here
  • Medicare Ground Ambulance Data Collection System webpage:
    • Printable version of the GADCS instrument in English and Spanish
    • GADCS User Guide
    • Tip sheets on reporting and getting access, FAQs, and prior educational sessions
    • Lists of ground ambulance organizations required to participate in Years 1–4

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.

CMS Announces Providers Selected for Year 3 & 4 Cost Data Collection

Centers for Medicare & Medicaid Services Announces Year 3 and Year 4 Medicare Ground Ambulance Data Collection System Selected Providers and Suppliers

The Centers for Medicare & Medicaid Services (CMS) has released the ground ambulance suppliers and providers selected for Years 3 and 4 of the Medicare ground ambulance data collection system.  The list of the selected providers and suppliers is available on the CMS website.  These providers and suppliers will be asked to collect data during their budget year starting in 2023 and to report the data within five months of the close of that year.

Providers and suppliers who are selected should respond to the notification letter sent by Medicare Administrative Contractors (MAC).  Organizations may select a calendar year or fiscal year start date for the data collection period.  Data will be submitted for a continuous 12-month period using the Medicare Ground Ambulance Data Collection Instrument: English (PDF).

The AAA continues to provide educational support for ground ambulance services to help them collect and report these data.  In addition to in-person sessions, the AAA offers webinars on demand.

It is important that all ground ambulance providers and suppliers collect and report data through this program.  The Congress intends to use the information to help reform Medicare ambulance fee schedule.

CMS Ambulance Open Door Forum Summary

On August 18, 2022, the Centers for Medicare and Medicaid Services (CMS) held its most recent Ambulance Open Door Forum (ODF). As is typically the case, CMS started the ODF with a series of announcements, before opening the call to questions from the ambulance industry.

 

The first announcement related to proposed changes to the regulations governing the medical necessity requirements for non-emergency, scheduled, repetitive ground ambulance services. Specifically, CMS is proposing to modify the so-called “special rule” for repetitive, scheduled non-emergency services (set forth in the regulations at 42 C.F.R. §410.40(e)(2)(ii)). CMS indicated that these proposed changes would provide necessary and ensure the consistent application of the documentation requirements by its contractors. The proposed change would add language indicating that both the Physician Certification Statement and “additional documentation from the beneficiary’s medical record” could be used to support medical necessity for the ambulance transport. The new language would further indicate that these documents must provide detailed explanations that are consistent with the beneficiary’s current medical condition. On the ODF, CMS encouraged the industry to submit comments on these proposed changes. However, CMS indicated that, because these changes were the subject of ongoing rulemaking, it would not be able to answer any questions on the ODF.

 

The second announcement related to the proposed changes to the Medicare Ground Ambulance Data Collection System (GADCS) included in the July 2022 Proposed Rule. CMS and its contractor, the Rand Corporation, went through a detailed PowerPoint presentation that summarized these proposed changes. That PowerPoint presentation can be accessed by clicking here.

 

As part of its discussion of the GADCS, CMS also announced the implementation of an automated process for requesting hardship exemptions and informal review of determinations that an ambulance provider is subject to a financial penalty for failing to properly submit its cost data.

 

The final announcement related to ambulance services furnished by Rural Emergency Hospitals (REHS). In the FY 2023 Outpatient Hospital Proposed Rule, CMS is proposing to codify in its regulations the statutory requirement that ambulance services furnished by entities that are owned and operated by REHS will be paid under the Medicare Ambulance Fee Schedule. CMS is also proposing to revise the origin and destination requirements to include REHS as both a covered origin and covered destination for ambulance services.

 

The ODF concluded with a brief Q&A period. All of the questions posed to CMS related to the GADCS.  One of the questions placed to CMS was whether it would permit ambulance suppliers to prospectively seek a hardship exemption, i.e., to permit an ambulance supplier to ask now that it be relieved of the financial penalties for failing to report its cost data. The person posing the question specifically referenced ambulance suppliers impacted by the severe flooding in the State of Kentucky. CMS confirmed that an ambulance supplier had to be notified that it was subject to a financial penalty before it was eligible to seek a hardship exemption.

CMS | Ambulance Ground Transport: Comparative Billing Report in April

From CMS on April 21, 2022

In late April, CMS will issue a Comparative Billing Report (CBR) on Medicare Part B claims for ambulance ground transport. Use the data-driven report to compare your billing practices with those of peers in your state and across the nation.

CBRs aren’t publicly available. Look for an email from cbrpepper.noreply@religroupinc.com to access your report. Update your email address in the Provider Enrollment, Chain, and Ownership System to ensure delivery.

For More Information:

AAA 2022 Legislative Priorities

Yesterday, the American Ambulance Association Board of Directors approved the Association’s advocacy priorities for 2022. Our key initiatives reflect the challenges we face this year, including short-sighted threats to EMS balance billing, a worsening workforce shortage, the expiration of the temporary Medicare increases, and potential sequestration cuts.

We also continue to fight for you as you care for people first on the frontlines of the COVID-19 pandemic. We will sustain our efforts at securing additional funding for ground ambulance services to help address the increased costs of providing medical care and transport during the Public Health Emergency.

To achieve our collective goals, the AAA Board will need to mobilize the full voice of influence of the EMS community this year. If you have not already sent an email using the AAA advocacy system to your members of Congress, please do so today!

Staff will be reaching out to you at key points later in the year about letter writing for specific individual policy requests. But it is important that they hear from you now on all the top issues for ground ambulance services.  They are:

Top AAA Advocacy Priorities for 2022

EMS Workforce Shortage

With the persistent shortage of ground ambulance service field personnel raising to a crisis level with the COVID-19 pandemic, the AAA moved the issue to a top policy priority. The AAA is currently working with key Congressional Committees of jurisdiction to hold hearings on the EMS workforce shortage. We are also developing legislation to specifically target increasing access for ground ambulance service organizations to federal programs and funding for the retention and training of health care personnel.

Balance Billing

The AAA successfully educated the Congress on the role of local government oversight and other unique characteristics of providing ground ambulance service organizations. As a result, the Congress directed the establishment of a Ground Ambulance and Balance Billing Advisory Committee to address the issue. The Committee is in the process of being formed and then has 180 days in which to make recommendations to the Congress. The AAA will be involved with the Committee and advocating that the Congress implement policies that meet the needs of our members.

Additional COVID-19 Financial Assistance

The AAA is advocating for additional financial assistance for ground ambulance service organizations to help address the increased costs of labor and other higher costs associated with providing health care during the COVID-19 pandemic.

Medicare Ambulance Relief

The temporary Medicare ambulance increases of 2% urban, 3% rural and the super rural bonus payment expire at the end of the year. The AAA will continue to push for passage of the provisions of the Preserving Access to Ground Ambulance Medical Services Act (S. 2037, H.R. 2454) before the provisions expire as well as for the adoption of language to ensure truly rural areas remain rural following changes to geographical designations based on the 2020 census.

Sequestration Cuts

The Congress delayed the additional 4% sequestration cut for only one yea. The AAA is working with other EMS and health care provider and supplier groups to permanently prevent the cut from going into effect as well as further extending the moratorium on the long-standing 2% cut.

Ambulance Cost Data Collection

With the 2-year delay of ambulance data collection due to the pandemic, the Medicare Payment Advisory Committee (MedPAC) will have little to no data to analyze in March 2023 in which to make recommendations to the Congress on Medicare ambulance payment policy and rates. The AAA is asking the Congress to push back the date of the MedPAC report and also expand the modified data collection timeline of two years to the intended four years.

On behalf of my fellow board members, I again thank you for your continued membership and participation. We look forward to serving you for many years to come.

We also encourage all of our AAA members to contact their members of Congress through our online advocacy tool. 

Should you have any questions regarding our advocacy priorities, please contact AAA Senior Vice President of Government Affairs Tristan North at tnorth@ambulance.org.

CMS | Data Collection Q&A December 14

From CMS
Medicare Ground Ambulance Data Collection System Webinar: Question and Answer (Q&A) Session  Tuesday, December 14, 2021 | 
2:00 PM – 3:00 PM ET

To register for this CMS Zoom webinar:

https://cms.zoomgov.com/webinar/register/WN_Jy_wpLZLQnuNu5vv_5Dbyw

After registering, you will receive a confirmation email containing information about joining the webinar.

Do you have questions about the Medicare Ground Ambulance Data Collection System? We are holding a live Q&A session on December 14, 2021 at 2:00 pm.  Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov  with “December 14 Q&A” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions using the “Q&A” button at the bottom of your Zoom screen.  In addition, we will update documents on our Ambulances Services Center webpage with answers to common questions from this session.

For more information, including the list of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 PFS Final Rule, the CY 2020 PFS final rule, and the Bipartisan Budget Act of 2018.

CMS | Medicare Ground Ambulance Data Collection Webinars October 7 & 12

From CMS on October 4, 2021

Dear Ground Ambulance Providers and Suppliers,

Please attend our October 7 webinar and October 12 Q&A session to learn about the Medicare Ground Ambulance Data Collection System. Both events will use Zoom. Starting January 1, 2023, selected ground ambulance organizations are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10% payment reduction.

Medicare Ground Ambulance Data Collection System Webinar: Labor Costs – October 7

Thursday, October 7 from 2­­­­­­­­­­-3pm ET

Register for this Zoom webinar.

During this webinar, CMS will walk through the Labor Cost section of the Medicare Ground Ambulance Data Collection Instrument (section 7). The presentation includes examples to help different types of ground ambulance organizations understand how to collect and report data for their paid and volunteer staff.

A Q&A session will follow this presentation. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 7 Labor Cost Webinar” in the subject line.

More information:

 

Medicare Ground Ambulance Data Collection System: Q&A Session – October 12

Tuesday, October 12 from 2-3pm ET

Register for the session.

Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 12 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.

More Information:

TODAY | CMS Cost Data Collection System Q&A Session

CMS Medicare Ground Ambulance Data Collection Q&A Session

Tuesday, September 14 from 2-3 pm ET

CMS is hosting a Q&A session about the Medicare Ground Ambulance Data Collection System tomorrow at 2:00pm Eastern.

Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “September 14 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.

More Information:

Register for this session

 

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