Updated CMS FAQs on the Ambulance Data Collection

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

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

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

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

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

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

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

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

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

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

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

New: 6/16/20

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

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

New: 6/16/20

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

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

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

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

Savvik Cost Collection Grant Application

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

Savvik Cost Collection Grant Request

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

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

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

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Ambulance Cost Collection Rule Summary

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

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Cost Data Collection Quick Take: NPIs

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

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Statement on Ambulance Cost Data Collection

October 22, 2018

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

For Immediate Release

Statement on Cost Data Collection for Ambulance Services

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

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

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

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

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

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

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About the American Ambulance Association (AAA)

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

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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…

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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…

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