CMS “Pauses” Prior Authorization Model for Scheduled, Repetitive Non-Emergency Ambulance Transportation

CMS released published a guidance document summarizing some of the steps that it has taken to relieve the administrative burden on health care providers and suppliers during the current public health emergency.  As part of that document, CMS indicated that it will be “pausing” the Prior Authorization Model for scheduled, repetitive non-emergency ambulance transports.  Under this program, ambulance suppliers are required to seek and obtain prior authorization for the transportation of repetitive patients beyond the third round-trip in a 30-day period.  Absent prior authorization, claims will be stopped for pre-payment review.  The Prior Authorization Model is currently in place in Delaware, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina, Virginia, West Virginia, and the District of Columbia. CMS indicated that this pause went into effect as of March 29, 2020, and will continue for as long as the current public health emergency continues.  During this pause, claims for repetitive, scheduled, non-emergency transports will not be stopped for pre-payment review if the prior authorization has not been requested and obtained prior to the fourth round-trip.  However, CMS indicated that claims submitted and paid during the pause without prior authorization will be subject to postpayment review. CMS further indicated that during this...

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CMS Announces New Healthy Adult Opportunity Initiative

On January 30, 2020, the Centers for Medicare and Medicaid Services (CMS) announced the roll-out of its “Healthy Adult Opportunity” (HAO) initiative.  Under the initiative, participating states will have a portion of their current federal Medicaid funding converted to block grants.  In return, the states will gain greater flexibility in providing for the health care needs of certain portions of their existing Medicaid populations. In a letter directed to State Medicaid Directors, CMS outlined the details of how the HAO initiative would operate.  The initiative will be operated under CMS’ 1115 waiver authority.  In order to participate, a state must submit an application setting forth the specific demonstration projects it intends to implement.  CMS reiterated that participation in the HAO initiative is voluntary.  CMS further indicated that it will review state applications on a case-by-case basis and make an independent decision on whether the proposed policies merit approval.  States with existing Section 1115 waivers that cover eligible populations will be permitted to transition existing demonstrations into the HAO initiative. CMS indicated that HAO demonstrations will generally be approved for an initial 5-year period, and successful demonstrations may be renewed for a period of up to 10 years. A summary of...

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CMS Cost Collection Call – December 5th

The Centers for Medicare and Medicaid Services has scheduled a call for Thursday, December 5 from 1:30-3:00 PM Eastern to review the new Ambulance Cost Data Collection System. If you plan to attend, register here. CMS Ambulance Cost Data Collection December 5 | 1:30 PM ET

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.

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....

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UPDATED: CMS Open Door Forum – Thursday, March 28

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, March 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 March 28 | 2:00 PM ET Participant Dial-In Number:  1-800-837-1935 Conference ID #: 6695896 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.

CMS to Host Additional ET3 Model Webinar (3/7)

The Centers for Medicare and Medicaid Services has scheduled an additional webinar on the new Emergency Triage, Treat, and Transport (ET3) Model announced on February 14, 2019. The webinar will be held on Thursday, March 7th at 2:00 PM Eastern. Registration is open. CMS ET3 Model Webinar March 7 | 2:00 PM ET

CMS ET3 Model Webinar & Follow Up AAA Member Q&A Call – Wednesday, Feb. 27

The Centers for Medicare and Medicaid Services has scheduled a webinar on the new Emergency Triage, Treat, and Transport (ET3) Model announced on February 14, 2019. The webinar will be held on Wednesday, February 27th at 1:00 PM Eastern. Registration is open. CMS ET3 Model Webinar February 27 | 1:00 PM ET Questions? Have more questions? The AAA is here to help! Following the ET3 Webinar, the AAA will host a Q&A conference call open to all members. AAA Follow Up Q&A February 27 | 3:00 PM ET 1-800-250-2600 Pin: 73556603# Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Rebecca Williamson; AAA Payment Reform Committee Chair, Asbel Montes....

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AAA Releases 2019 State Medicaid Ambulance Rate Survey

The AAA is pleased to release its 2019 State Medicaid Rate Survey. This survey sets forth the fee-for-service Medicaid rates for all 50 states. For each state, the Survey lists the rate paid for each of the following procedure codes: A0428 – BLS Non-Emergency A0429 – BLS Emergency A0426 – ALS Non-Emergency A0427 – ALS Emergency A0433 – ALS-2 A0434 – SCT A0225 – Neonate Transport A0998 – Treatment, No Transport A0425 – Mileage A0422 – Oxygen A0382/A0398 – BLS/ALS Routine Disposable Supplies A0420 – Wait Time A0424 – Extra Attendant The rates set out in this survey are based on publicly available information provided by the various State Medicaid agencies. While the AAA has taken steps to verify the accuracy of the information on this Survey, it is possible that the rates provided in the Survey may not reflect changes to a state’s reimbursement policies that have not been made publicly available. These rates may not also not reflect any emergency budgetary measures or other temporary reductions imposed by a state. The AAA’s goal is to make this Survey as accurate as possible. Therefore, if you believe the rates for your state are inaccurate, please contact the AAA at...

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Reports of Ambulance Pilot Programs

Earlier this week, health care trade press reported that the Centers for Medicare and Medicaid Innovation (CMMI) will be rolling out in the coming weeks several innovation pilot programs including a couple related to ambulance services. Over the last several months, the AAA has been meeting with CMMI and CMS officials about a pilot or change in policy to allow for coverage of transports by ambulance to destinations other than emergency departments. These efforts have coincided with efforts by others in the industry on alternative destination as well as reimbursement on some form of treat and refer of a patient. The AAA is pleased that CMMI and CMS have listened to the recommendations of the AAA and other groups in moving forward on testing different policy changes. However, it is critical that the AAA and our members see the specifics of any pilot programs before we determine whether to support the initiative. CMMI cannot provide details of the program until available publicly and all the specifics of such programs are critical to whether they will be a success and if it will be a positive change for the industry and our ability to provide quality patient care. We will provide you details of the pilot programs and the position of (more…)

CMS Extends Moratorium on Non-Emergency Ground Services

CMS Extends Temporary Moratorium on Non-Emergency Ground Ambulance Services in New Jersey and Pennsylvania The Centers for Medicare & Medicaid Services (CMS) has announced that it intends to extend the temporary moratoria on the enrollment of new Medicare Part B non-emergency ground ambulance providers and suppliers in the states of New Jersey and Pennsylvania.  The extended moratoria will run through January 29, 2019.  Notice of the extension of the temporary moratorium will appear in the Federal Register on August 2, 2018. Section 6401(a) of the Affordable Care Act granted CMS the authority to impose temporary moratoria on the enrollment of new Medicare providers and suppliers to the extent doing so was necessary to combat fraud or abuse.  On July 31, 2013, CMS used this new authority to impose a moratorium on the enrollment of new ambulance providers in Houston, Texas and the surrounding counties.  On February 4, 2014, CMS imposed a second moratorium on newly enrolling ambulance providers in the Philadelphia metropolitan areas.  These moratoriums were subsequently extended on August 1, 2014, February 2, 2015, July 28, 2015, and February 2, 2016. On August 3, 2016, CMS announced changes to the moratoria on the enrollment of new ground ambulance suppliers. ...

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Physician Fee Schedule Proposed Rule 2018

On Thursday, July 12, the Centers for Medicare & Medicaid Services (CMS) released the “Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program” Proposed Rule (Proposed Rule). As you know, the American Ambulance Association worked closely with the Congress to ensure passage of the Bipartisan Budget Act of 2018 (BBA) (Pub. L. 115-123, enacted on February 9, 2018). The BBA not only extended the ambulance add-ons for 5 years, but also authorized a cost collection system that would not be overly burdensome on ambulance providers and suppliers, but would provide sufficient information ideally to support the permanent extension of the add-ons and set the basis for new payment models, including alternative destinations, treatment/assessment without transport, and community paramedicine. After passage of the BBA, the AAA engaged immediate with CMS to ensure the smooth implementation of these provisions. Those contacts resulted in guidance earlier this year implementing the add-ons retroactively to January 1, 2019. Consistent with the statute and already-released guidance, the Proposed Rule extends the three add-ons: the 2 percent urban, 3 percent rural, and 22.6 percent super-rural...

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CMS Open Door Forum & Follow Up AAA Member Q&A Call – Thursday, June 14

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, June 14 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 June 14 | 2:00 PM ET Participant Dial-In Number:  1-800-837-1935 Conference ID #: 33271311 Questions? Have more questions? The AAA is here to help! Following the Open Door Forum, the AAA will host a Q&A conference call open to all members. AAA Follow Up Q&A June 14 | 3:00 PM ET 1-800-250-2600 Pin: 73556603# Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Medicare Consultant, Brian Werfel, Esq.; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Rebecca Williamson; and AAA Medicare Regulatory Committee Vice-Chair, Angie McLain

March CMS Ambulance Open Door Forum & Follow Up Q&A

The next CMS Ambulance Open Door Forum is scheduled for Wednesday, March 7 at 2:00 PM Eastern. Please dial in at least 15 minutes before the call. View Agenda. CMS Ambulance Open Door Forum March 7 | 2:00 PM ET 1-800-837-1935 Conference ID: 31612304 Questions? Have questions after the CMS Open Door Forum? The AAA is here to help! Following the Open Door Forum, the AAA will host a Q&A conference call open to all members. AAA Follow Up Q&A March 7 | 3:00 PM ET 1-800-250-2600 Pin: 73556603#

December CMS Ambulance Open Door Forum & Follow Up Q&A

The next CMS Ambulance Open Door Forum is scheduled for Thursday, December 14 at 2:00 PM Eastern. Please dial in at least 15 minutes before the call. View Agenda. CMS Ambulance Open Door Forum December 14 | 2:00 PM ET 1-800-837-1935 Conference ID: 61764351 Questions? Have questions after the CMS Open Door Forum? The AAA is here to help! Following the Open Door Forum, the AAA will host a Q&A conference call open to all members. AAA Follow Up Q&A December 14 | 3:00 PM ET 1-800-250-2600 Pin: 82802314#

Response to Kaiser Health News Ambulance Billing Article

To the Editor: I write today in response to Melissa Bailey’s November 20 piece about ambulance balance (“surprise”) billing. While we disagree with the characterization of ambulance services in the article, we welcome the ongoing public dialogue about how unsustainable reimbursement for emergency medical services results in cost-shifting to patients. Missing from the article is a true understanding of the sky-high cost of readiness for emergency medical services. Ambulance service providers offer their communities 24/7/365 on-demand mobile healthcare. Skilled staff and ambulances—high-tech emergency rooms on wheels—are ready to respond to a 9-1-1 call at a moment’s notice to help patients with issues ranging from stroke to heart attack to trauma to childbirth. EMS is also on the very front lines of the surge in opioid overdoses, providing naloxone (Narcan) to hundreds of patients each day. Keeping supplies, medications, equipment, and personnel at-the-ready requires a significant ongoing investment, regardless of whether or not an ambulance is out responding to a call. Cost comparisons between EMS and the rideshare app Uber may make for catchy sound bites, but they are misleading and misguided. The piece states that our nation’s 14,000 ambulance service providers received 1,200 Better Business Bureau complaints spread over three (more…)

Time to handle 911 call demands with Paramedics

When discussing this new and growing field of pre-hospital care, there seems to be two unique paths that services are following. The first is the hospital-owned or contracted service, where community providers seek ways to decrease readmission rates for CHF, COPD, Pneumonia, Sepsis, MI and other chronic illnesses. When a patient discharged with one of these targeted conditions is readmitted within a 30 day window, “hospitals face penalties of up to 3 percent of Medicare payments in 2018” (Gluck, 2017, para. 10). That is a lot of money. Consider, “Lee Health, Southwest Florida’s largest hospital operator, which is expected to lose $3.4 million in payments” (Gluck, 2017, para. 2). This model represents the if, or, and type of service, meaning if we can do it for less and there are providers willing to do this type of medicine, then we can save the expensive penalties from CMC. The other model of community paramedicine is 911 abuse reduction. For years EMS has conditioned the public to call 911 for any emergency. But today, what we consider an emergency is far from the public’s perception of an emergency. “EMS has experienced a 37% increase in 911 calls since 2008.” (White, 2016, para. (more…)