Updated CMS FAQs on the Ambulance Data Collection

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

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

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

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

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

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

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

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

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

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

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

New: 6/16/20

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

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

New: 6/16/20

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

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

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

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

Savvik Cost Collection Grant Application

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

Savvik Cost Collection Grant Request

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

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

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

Our research indicated that due to 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.

Statement on Ambulance Cost Data Collection

October 22, 2018

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

For Immediate Release

Statement on Cost Data Collection for Ambulance Services

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

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

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

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

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

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

###

About the American Ambulance Association (AAA)

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

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.

Payment Reform Chairs Pen Op-Ed in JEMS

Ambulance payment reform is critical to the future of emergency medical services across our country. Don’t miss the op-ed in JEMS by Asbel Montes and Jimmy Johnson, chair and vice chair of AAA’s Payment Reform Committee.

Before the industry as a whole can embrace mobile integrated health, community paramedicine, and value-based purchasing, the industry must contend with standardizing cost data and submitting it to the federal government. We must also fight to ensure that payment is linked to the health care services provided and less to the act of transporting patients.

Read the full op-ed►

Ready to add your voice to the conversation? Join fellow members at AAA’s Payment Reform Town Hall at EMS Today in Salt Lake City. Learn more►

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.