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

 

CMS Webinar | Cost Collection Q&A

From CMS

Medicare Ground Ambulance Data Collection SystemQuestion and Answer Session on September 14, 2021 2:00 PM – 3:00 PM ET.

To participate in the Q&A session, you must register for the session at: https://cms.zoomgov.com/webinar/register/WN_tuyiGdvORRiTXbmPaTQ1zg.

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 September 14, 2021 at 2:00 pm.  Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “September 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 in the “chat” box.  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 lists of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf, and the CY 2020 Physician Fee Schedule final rule.

CMS Webinar | Cost Collection Instrument Walk-Through

From CMS

Medicare Ground Ambulance Data Collection System Webinar: Instrument Walkthrough

Thursday, August 26, 2021 from 2:00 PM-3:30 PM ET.

To register for this webinar: https://cms.zoomgov.com/webinar/register/WN_S0aGs_TWTpWRBWF5hDAf3Q.

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

The slide presentation is available here. (PDF)

During this call, CMS will walk through the Medicare Ground Ambulance Data Collection Instrument section-by-section, focusing on select instructions, data collection guidelines, and common questions and answers. The webinar will also highlight proposed changes to the instrument in the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf.

A question-and-answer session will follow this presentation. You may send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “August 26 Instrument Webinar” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions in the “chat” box.

For more information, including ground ambulance organizations that must report, see the Ambulances Services Center webpage, CY 2020 Physician Fee Schedule final rule, and Bipartisan Budget Act of 2018.

CMS Open Door Forum | Medicare Ground Ambulance Data Collection System

August 12, 2021 Ambulance Open Door Forum

August 12, 2021 | 14:00–15:30 ET

Slide presentation on the Overview of the Medicare Ground Ambulance Data Collection System (PDF) is now available.

The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, August 12, 2021
Start Time: 2:00pm-3:30pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham

Agenda

**This Agenda is Subject to Change**

I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market-based Pricing
Moderator – Jill Darling (Office of Communications)

II. Announcements & Updates

  • Emergency Triage, Treat, and Transport (ET3) Model Update
    • ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
      • ET3Model@cms.hhs.gov for inquiries
      • ET3 Model Listserv for Model updates: https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12521

 

Overview of the Medicare Ground Ambulance Data Collection
System
 A copy of the presentation will be available on the
Ambulances Services Center website under
Spotlights: https://www.cms.gov/Center/ProviderType/Ambulances-Services-Center
III. Open Q&A

**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
———————————————————————
This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.

Open Door Participation Instructions

This call will be Conference Call Only.

To participate by phone:
August 12, 2021 | 14:00–15:30 ET | Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
Persons participating by phone do not need to RSVP. TTY Communications Relay
Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.

Instant Replay

1-866-470-7051; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
866-470-7051 and entering the Conference Passcode beginning 1 hours after the
call has ended. The recording is available until August 14, 2021, 11:59PM ET.

For ODF schedule updates and E-Mailing List registration, visit our website at
http://www.cms.gov/OpenDoorForums/.

Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. Please allow up to three weeks to get both the
audio and transcript posted to: https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

 

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 are working together to support 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 FREE access to Amber, the cost collection software. Services will be eligible to receive a one-year AAA membership, which includes access to experts on cost collection, access to AMBER software, and free registration to Webinars and Regional Workshops. To request your FREE access to Amber, complete the application form below.

Savvik Cost Collection Grant Request

  • Was your organization (at least one NPI) selected by CMS for cost collection?
  • Choose the category that best applies to your service
  • 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 industry capacity, a provider sample and survey approach would be preferable to a mandatory cost reporting structure. Congress agreed! Our research indicated that different organizational structures made us unique healthcare providers and as such, EMS’s special nature should be considered in the collection tool developed. Congress agreed! No one knows our industry better than we do and the final rule from the Centers for Medicare and Medicaid Services indicates they listened!

So your ambulance service was selected for the 2020 reporting period—now what? Here is your 10 STEP PLAN.

STEP 1: Sign up for the latest information on ambulance cost data collection.

Subscribe to email updates from the American Ambulance Association’s Ambulance Cost Education page, www.ambulancereports.org. Not only will we make sure you get the latest information disclosed from the Centers for Medicare & Medicaid Services, but we will also provide you with quick tutorials on how to fill out the cost data collection instrument. Most importantly, you can purchase AMBER! This software provides an easy, quick solution for you to input your data, with built-in tutorials to walk you through the data collection process.

STEP 2: Know what is included in your National Provider Identification (NPI) number.

It is important that you review the information in the Provider Enrollment, Chain, and Ownership System (PECOS) which supports the Medicare Provider and Supplier enrollment process. You will want to make sure the information that you provide in the cost data collection tool, at a minimum, matches what is in this system or on your CMS 855B Medicare enrollment application. Pay close attention to the following:

  1. Practice location(s)
  2. Vehicle Information
  3. Ownership

STEP 3: “Tele” a Friend!

More than 2,600 ambulance suppliers and providers were selected for the 2020 reporting period (Zip file download of services selected for 2020). Please reach out to your colleagues. Now is not the time to let competition or friendly rivalries stop us from communicating best practices. Call your fellow mobile healthcare providers!

STEP 4: Know your accounting “status.”

How you recognize cost and revenue will be extremely important in determining how you report. Cash accounting recognizes revenue and expenses only  when money actually exchanges hands. Accrual accounting recognizes revenue and expenses when billed, not when money exchanges hands. This status will be key in determining how you report costs and revenues.

STEP 5: Know your mileage.

For every ambulance and non-ambulance vehicle that you use related to patient care, you will need to know the odometer readings at the beginning and end of 2020. Make sure you have a system to record the odometer readings accurately.

For example, you have a 2016 ambulance where the odometer reading on 1/1/2020 is 10,212. If on 12/31/2020 the odometer reading is 74,112, you will have the option of recording the full mileage of 63,900 in the data collection tool. This is another window into the “cost of readiness.”

STEP 6: Set up and Identify payer categories.

As identified by the Medicare Ground Ambulance Data Collection System (PDF download), there are nine payer type categories for billing ambulance transportation. Know these categories and set them up in your system now, prior to billing for ambulance transports in 2020. If you use a billing agency, seek confirmation that they have a way to identify these nine payer types. You may not have select reports to identify the numbers yet within these categories but that can be set up later in the reporting year.

Setting up your system NOW to identify these payer categories is critical as it will be too administratively burdensome to fix this retroactively.

STEP 7: Know if you share support services or stand alone.

Support services are services such as maintenance, dispatch, billing, materials management, human resources and other services that support patient care. You will need to know if you share these services with other entities such as fire, police, air ambulance, hospital or other entity not related to ground ambulance care.

If you share, then you will have to work out an allocation model to assign the costs and revenue appropriately. If you do not share support services, then you do not need to work about any of the questions related to allocation.

STEP 8: Identify sources of revenue and cost categories.

Check your systems. Now is the time to make sure you can identify all sources of revenue you receive whether from billing for an ambulance transport or from a grant or local tax. Understand your costs, especially those related to salary, vehicles, facilities and medical supplies. That is the first step in the ability to categorize appropriately.

STEP 9: Don’t panic!

Take a deep breath—It is not as complicated as it may seem. There are resources available and assistance for you and your ambulance services as outlined in STEP 1.

STEP 10: Repeat Step 1!

See, that wasn’t too bad, was it? Now you have a 10 Step Plan!

In all seriousness, while it may seem a bit daunting at first, breaking down the cost data collection process into small steps will ensure that our industry is prepared and the figures we enter into this cost data collection tool will glean useful information. It is imperative that we get this right the first time to avoid any unintended consequences, such as decreased reimbursements and other impactful changes that could harm the patients we serve.

As the saying goes, “the rising tide lifts all boats.” More than ever, we need to help and assist our colleagues as we navigate this new world of ambulance reimbursement.

So, what’s next? Cost data collection, my friend! Jump on board.

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 in the November 15 issue of the Federal Register.
The AAA will continue to keep you informed about the implementation of the Ambulance Data
Collection System.

Final Rule Summary

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?

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

August 28 | 3:00 PM ET
1-800-250-2600
Pin: 82802314#
Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Krista Cuthbert; and AAA Payment Reform Committee Chair, Asbel Montes.

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 also proposes the cost and revenue data elements it plans to use.  There are some details in the proposed rule text and others will be in the proposed tool that will be posted the CMS website today.

CMS also proposes the collection period and penalties for failing to report.

While the data collection provision was the key component for ground ambulance services, CMS also proposed changes to the PCS requirement sought by the AAA. CMS is proposing to reference the PCS also as non-physician certification agreements. The agency is further proposing to clarify that the focus is on the certification of the medical necessity provisions and the form of the certification statement is not prescribed.  As part of the non-physician statement, CMS is proposing expanding the staff of you may sign the statement when an attending physician is unable to sign.

Download Full PDF Summary by Kathy Lester, Esq.

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