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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 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:

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

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.

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.

Collecting Data for the Future

Collecting Data for the Future:  Understanding the New Statutory Cost Collection Requirement

By Kathy Lester, JD, MPH, Lester Health Law PLLC

On February 9, the President signed into law the Bipartisan Budget Act of 2018 which thankfully included a five-year extension of the ambulance add-ons.  Along with the add-ons extension, the Congress included language requiring the Centers for Medicare and Medicaid Services (CMS) to develop and implement a new cost data collection system for ambulance service providers and suppliers.  While cost collection may sound difficult, the process outlined in the new authority strikes the appropriate balance and will minimize the burden on ambulance service providers and suppliers, while allowing the federal government to collect meaningful data that can be used to address the inadequate reimbursement rates and modernize Medicare ambulance payment policies.

Knowing some time ago that the industry would need to provide CMS with cost information, the AAA for the past six years has been working with The Moran Company, a well-respected health care analytical firm in DC, on the best way to collect ambulance cost data.  Most recently, the AAA Payment Reform Committee has been working with the cost collection experts at The Moran Company to identify the data elements that CMS would need to collect to establish accurate information about the cost of providing ground ambulance services.  We have also developed educational materials that we will share with Members to help ensure a smooth transition into this system.

General

The core components of the new cost collection system for providers and suppliers of ground ambulance services are:

  • A requirement that the Secretary of Health and Human Services, through notice-and-comment rulemaking, must develop a data collection system to collect:           (1) cost; (2) revenue; (3) utilization; and (4) other information determined appropriate by the Secretary;
  • This system may use a cost survey; and
  • The data collect should include information: (1) needed to evaluate the extent to which costs are related to payment rates; (2) on the utilization of capital equipment and ambulance capacity; and (3) on different types of ground ambulance services furnished in different geographic locations and low population density areas.

Representative Sample

Under the statute, the Secretary must select a representative sample of providers and suppliers from whom to collect data.  The sample will be determined based on the type of providers and suppliers (such as those that are part of a governmental organization, fire, hospital-based, etc) and the geographic locations (such as urban, rural, and low-population density areas).  An individual provider or supplier (defined most likely by National Provider Identifier) may not be requested to submit data in two consecutive years, to the extent practicable.

Reporting Requirements

A provider or supplier selected to report data must do so in the form and manner and at the time specified by the Secretary.  If a provider or supplier that has been selected to report does not do so, then the provider or supplier may be subject to a 10 percent payment reduction, unless the hardship exemption applies.  Providers or suppliers that are penalized may seek a review of the application of the penalty.  The Secretary does have the authority to take into consideration certain hardships as to why a provider or supplier was unable to submit their data and waive the penalty.

Modification Over Time

The Secretary may revise the system over time.

Public Availability of the Data

The Secretary will provide the information collected available through the CMS Website, similar to the process used for other data CMS collects.

MedPAC Report

In addition, the language includes a study/studies from the Medicare Payment Advisory Commission (MedPAC).  MedPAC is required to issue at least one report, and potential subsequent reports, on the following:

  • An analysis of the information submitted by providers and suppliers through the data collection system;
  • An analysis of any burden on providers and suppliers associated with the data collection system;
  • A recommendation as to whether information should continue to be submitted through such data collection system or if it should be revised;
  • The adequacy of payments for ground ambulance services;
  • Geographic variations in the cost of furnishing ground ambulance services; and
  • Other information determined appropriate by the Commission.

Timeline

The Secretary must implement the data collection system according to the following timeline:

The AAA will continue to keep you informed as the development and implementation of the ambulance cost data collection system moves forward.

12/31/2019
  • Specify the data collection system
  • Identify providers and suppliers that would be required to submit information for the representative sample

2020 – 2024

 

  • Collect data each year from a representative sample of providers and suppliers
 2022  

  • First year a provider or supplier that has been asked to submit data and has not sufficiently submitted the data may be subject to a 10 percent payment reduction.
 2023  

  • MedPAC report due
 2025+  

  • Collect data as the Secretary determines appropriate but no less often than once every 3 years

The AAA will continue to work with The Moran Company and other experts to make sure data collection system works for all ambulance service providers and suppliers and leads to information that the industry needs to move toward making the add-ons permanent and modernizing the benefit to include new payment models, including transports to alternative destinations, treatment with referral and no transport, and mobile integrated health.

CMS Releases Ambulance Cost Data Collection Report

The Centers for Medicare and Medicaid Services (CMS) has released its report on the feasibility of collecting cost data from ambulance service providers.  Under the American Taxpayer Relief Act of 2012, Congress directed CMS to conduct the report entitled “Evaluation of Hospitals’ Ambulance Data on Medicare Cost Reports and Feasibility of Obtaining Cost Data from All Ambulance Providers and Suppliers”. The report can be accessed here.

The report states that due to the diverse nature of our industry with a majority of providers being small entities, traditional mandatory ambulance cost reporting is not feasible.  While it does not make a recommendation on a data collection system, the report highlights the work of the AAA with The Moran Company and will be helpful in our push for a survey approach to collecting ambulance cost data.  Here is AAA’ summary of the report, AAA Summary of CMS Acumen Cost Analysis.

The survey approach to collecting ambulance cost data is a major component of the Medicare Ambulance Access, Fraud Prevention and Reform Act (S. 377, H.R. 745) which would make the current Medicare ambulance increases permanent.  The data collected through the survey would help the AAA make data-driven recommendations to the Congress and CMS on future changes to the Medicare ambulance fee schedule.

The contractor, Acumen, who developed the report, was also asked to look to see if cost data submitted by hospital-based ambulance service providers would be helpful.  Acumen determined that the data submitted varied significantly and thus was not useful.

For questions about the AAA efforts on cost data collection, please contact AAA Senior Vice President of Government Affairs Tristan North at tnorth@ambulance.org.

The Importance of Ambulance Cost Survey Data

By Kathy Lester, JD, MPH | Updated November 9, 2015

Tomorrow is in your hands today. This statement is especially true when we think about the evolution of ambulance services. Today, care once reserved for the hospital setting is now delivered at the scene, resulting in better patient outcomes. Yet, despite these advances, the Medicare payment system lags behind. Current rates are based upon a negotiated rulemaking process that did not take the cost of providing services into accounts. While many in the industry strive to further expand the delivery of high-quality care, the inflexibility of the current payment system makes it difficult to compensate the next generation of ambulance service providers appropriately.

To prepare for tomorrow, ambulances services must act today. The AAA has taken a leadership role by setting the groundwork needed to reform the payment system so that it recognizes the continued evolution of ambulance services. The two game changers are (1) designating ambulance suppliers as “providers” of care; and (2) implementing a federal data collection system.

“Emergency care has made important advances in recent decades: emergency 9-1-1 service now links virtually all ill and injured Americans to immediate medical response; organized trauma systems transport patients to advanced, lifesaving care within minutes; and advances in resuscitation and lifesaving procedures yield outcomes unheard of just two decades ago.”
Institute of Medicine: Emergency Medical Services at a Crossroads (2007)

Provider Status

Being deemed a “provider” rather than a “supplier” is the first step toward recognizing the clinical component of ambulance services and appropriately incorporating ambulance services into the broader health care coordination and reform discussions.

Under current law, the term provider refers to hospitals, skilled nursing facilities (SNFs), outpatient rehabilitation facilities, home health agencies, ambulatory surgical centers, end-stage renal disease facilities, organ procurement organizations, and clinical labs. Durable medical equipment entities and ambulance services are designated as suppliers.

When ambulance services were first added to the Medicare benefit, the primary services provided were transportation. As noted already, transportation is only one component of the services provided. The deliver of health care services today make ambulances more like other Medicare providers than suppliers.

Achieving this designation is the first step toward having the federal government recognizing the value of the health care services provided by ambulances.

Cost Collection

The second game changer involves collecting cost data from all types and sizes of ambulances services in all areas of the country. Current Medicare rates are not based on cost. As the Government Accountability Office has recognized in two separate reports, these rates do not cover the cost of providing services to beneficiaries. While the Congress has extended the ambulance add-ons year after year, the lack of a permanent fix makes it difficult to plan. There is also the risk of the add-ons not being extended at some point. In addition, the rates take into account only at the most general level the health care being provided.

In the American Taxpayer Relief Act (ATRA), the Congress required the Centers for Medicare and Medicaid Services (CMS) to issue a report evaluating the ability to use current hospital cost reports to determine rates and also to assess the feasibility of obtaining cost data on a periodic basis from all types of ambulance services. Knowing of the strong Congressional interest in obtaining additional cost information, the AAA began working with The Moran Company (a consultant organization with expertise in Medicare cost reporting) to develop recommendations as to how cost data could be most efficiently and effectively collected. The AAA shared these recommendations with CMS and the contractor developing the report. The final report, released in October, supports the AAA’s work and states:

Any cost reporting tool must take into account the wide variety of characteristics of ambulance providers and suppliers. Efforts to obtain cost data from providers and suppliers must also standardize cost measures and ensure that smaller, rural, and super-rural providers and suppliers are represented.

The next step in the process is to provide CMS with direction and authority to implement the AAA’s cost survey methodology. In brief, the methodology would:

  • Require all ambulance services to report to CMS demographic information, such as organizational type (governmental agency, public safety, private, all volunteer, etc), average duration of transports, number of emergency and nonemergency transports. CMS would use this data to establish organization categories so that the data collected aligns with the type of organization providing it.
  • Require all ambulance services to report cost data, such as labor costs, administrative costs, local jurisdiction costs, through a survey process. During any survey period, CMS would identify a statistically valid sample of ambulance services in each category to be surveyed. These services would have to provide the data or be subject to a five percent penalty. Those ambulance services that provide data will not be asked to do so again until every service in its organization category has submitted the data.

As part of this process, the AAA has begun developing a common language for reporting these data. This work will ensure that the information is collected in a standardized manner. The AAA will also provide assistance to services that may need extra help in completing the surveys.

This information can then be aggregated and used to evaluate the adequacy of Medicare payments and support additional coverage policies. Most importantly, it will allow policy-makers, the AAA, and other stakeholders to reform the current Medicare ambulance payment system so that it incorporates the health care services currently being provided and those that will be in the future.

Conclusion

In order to be prepared for the reimbursement structures of tomorrow, ambulance services need to be designated a providers and recognized for the health care they provide. They also need to participate in a standardized cost collection program that will provide accurate data in the least burdensome way possible. The AAA is leading the effort to help ambulance services prepare for tomorrow.

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