Medicare Ambulance Relief Bill introduced in Senate

Yesterday, Senators Catherine Cortez Masto (D-NV) and Susan Collins (R-ME) introduced the Protecting Access to Ground Ambulance Medical Services Act of 2021 (S. 2037). Senators Cortez Masto and Collins were joined by Senators Debbie Stabenow (D-MI), Bill Cassidy (R-LA), Patrick Leahy (D-VT) and Bernie Sanders (D-VT) as primary cosponsors and leads on the legislation.

S. 2037 is identical to H.R. 2454 by Representatives Terri Sewell (D-AL), Devin Nunes (R-CA), Peter Welch (D-VT) and Markwayne Mullin (R-OK) and would extend the temporary Medicare ground ambulance increases of 2% urban, 3% rural and the super rural bonus payment for five years. The increases are currently scheduled to expire on December 31, 2022. The five-year extension would allow for the increases to remain in place during the two-year delay on ambulance data collection due to the COVID-19 public health emergency, an analysis of the data by MedPAC and subsequent action by the Congress to reform the Medicare ambulance fee schedule.

The legislation would also help ensure that rural zip codes in large urban counties remain rural following geographical changes under the fee schedule as a result of the 2020 census data. The current definition using rural urban commuting areas (RUCA) in Goldsmith Modification areas would be modified for zip codes with 1,000 people or less per square mile would also be rural. Ground ambulance service providers and suppliers could also petition the Centers for Medicare and Medicaid Services (CMS) to make the argument that a specific zip code should be rural. It is vital that this provision be implemented before CMS makes changes from the 2020 census data which will likely occur in 2023.

The AAA has been leading the effort on the legislation with the support of the International Association of Fire Chiefs, International Association of Fire Fighters, National Association of EMTs, National Rural Health Association and the National Volunteer Fire Council.

The AAA will be launching a Call to Action shortly requesting AAA members to ask their Senators to cosponsor S. 2037, and reach out to their Representatives to cosponsor H.R. 2454 if they have not already done so.

We greatly appreciate the leadership of Senators Cortez Masto, Collins, Stabenow, Cassidy, Leahy, and Sanders on this vitally important legislation.

CMS Bolsters Payments for At-Home COVID-19 Vaccines

From CMS on June 9, 2021

Biden Administration Continues Efforts to Increase Vaccinations by Bolstering Payments for At-Home COVID-19 Vaccinations for Medicare Beneficiaries

As part of President Biden’s commitment to increasing access to vaccinations, CMS announced an additional payment amount for administering in-home COVID-19 vaccinations to Medicare beneficiaries who have difficulty leaving their homes or are otherwise hard-to-reach. This announcement further demonstrates continued efforts of the Biden-Harris Administration to meet people where they are and make it as easy as possible for all Americans to get vaccinated. There are approximately 1.6 million adults 65 or older who may have trouble accessing COVID-19 vaccinations because they have difficulty leaving home.

While many Medicare beneficiaries can receive a COVID-19 vaccine at a retail pharmacy, their physician’s office, or a mass vaccination site, some beneficiaries have great difficulty leaving their homes or face a taxing effort getting around their communities easily to access vaccination in these settings. To better serve this group, Medicare is incentivizing providers and will pay an additional $35 per dose for COVID-19 vaccine administration in a beneficiary’s home, increasing the total payment amount for at-home vaccination from approximately $40 to approximately $75 per vaccine dose. For a two-dose vaccine, this results in a total payment of approximately $150 for the administration of both doses, or approximately $70 more than the current rate.

“CMS is committed to meeting the unique needs of Medicare consumers and their communities – particularly those who are home bound or who have trouble getting to a vaccination site. That’s why we’re acting today to expand the availability of the COVID-19 vaccine to people with Medicare at home,” said CMS Administrator Chiquita Brooks-Lasure. “We’re committed to taking action wherever barriers exist and bringing the fight against the COVID-19 pandemic to the door of older adults and other individuals covered by Medicare who still need protection.”

Delivering COVID-19 vaccination to access-challenged and hard-to-reach individuals poses some unique challenges, such as ensuring appropriate vaccine storage temperatures, handling, and administration. The CDC has outlined guidance to assist vaccinators in overcoming these challenges. This announcement now helps to address the financial burden associated with accommodating these complications.

The additional payment amount also accounts for the clinical time needed to monitor a beneficiary after the vaccine is administered, as well as the upfront costs associated with administering the vaccine safely and appropriately in a beneficiary’s home. The payment rate for administering each dose of a COVID-19 vaccine, as well as the additional in-home payment amount, will be geographically adjusted based on where the service is furnished.

How to Find a COVID-19 Vaccine:

As this action demonstrates, a person’s ability to leave their home should not be an obstacle to getting the COVID-19 vaccine. As states and the federal government continue to break down barriers – like where vaccines can be administered – resources for connecting communities to vaccination options remain key. Unvaccinated individuals and those looking to assist friends and family can:

  • Visit vaccines.gov (English) or vacunas.gov (Spanish) to search for vaccines nearby
  • Text GETVAX (438829) for English or VACUNA (822862) for Spanish for near-instant access to details on three vaccine sites in the local area
  • Call the National COVID-19 Vaccination Assistance Hotline at 1-800-232-0233 (TTY: 1-888-720-7489) for assistance in English and Spanish

Coverage of COVID-19 Vaccines:

The federal government is providing the COVID-19 vaccine free of charge or with no cost-sharing for all people living in the United States. As a condition of receiving free COVID-19 vaccines from the federal government, vaccine providers cannot charge patients any amount for administering the vaccine.

Because no patient can be billed for COVID-19 vaccinations, CMS and its partners have provided a variety of information online for providers vaccinating all Americans regardless of their insurance status:

  • Original Medicare and Medicare Advantage: Beneficiaries with Medicare pay nothing for COVID-19 vaccines or their administration, and there is no applicable copayment, coinsurance or deductible.
  • Medicaid and the Children’s Health Insurance Program (CHIP):State Medicaid and CHIP agencies must cover COVID-19 vaccine administration with no cost sharing for nearly all beneficiaries during the COVID-19 Public Health Emergency (PHE) and for over a year after it ends. For the very limited number of Medicaid beneficiaries who are not eligible for this coverage (and do not receive it through other coverage they might have), providers may submit claims for reimbursement for administering the COVID-19 vaccine to underinsured individuals through the COVID-19 Coverage Assistance Fund, administered by the Health Resources and Services Administration (HRSA), as discussed below. Under the American Rescue Plan Act of 2021 (ARP), signed by President Biden on March 11, 2021, the federal matching percentage for state Medicaid and CHIP expenditures on COVID-19 vaccine administration is currently 100% (as of April 1, 2021), and will remain 100% for more than a year after the COVID-19 PHE ends. The ARP also expands coverage of COVID-19 vaccine administration under Medicaid and CHIP to additional eligibility groups. CMS recently updated the Medicaid vaccine toolkit to reflect the enactment of the ARP at https://www.medicaid.gov/state-resource-center/downloads/covid-19-vaccine-toolkit.pdf.
  • Private Plans: The vaccine is free for people enrolled in private health plans and issuers COVID-19 vaccine and its administration is covered without cost sharing for most enrollees, and such coverage must be provided both in-network and out-of-network during the PHE. Current regulations provide that out-of-network rates must be reasonable as compared to prevailing market rates, and the rules reference using the Medicare payment rates as a potential guideline for insurance companies. In light of CMS’s increased Medicare payment rates, CMS will expect health insurance issuers and group health plans to continue to ensure their rates are reasonable when compared to prevailing market rates. Under the conditions of participation in the CDC COVID-19 Vaccination Program, providers cannot charge plan enrollees any administration fee or cost sharing, regardless of whether the COVID-19 vaccine is administered in-network or out-of-network.

The Biden-Harris Administration is providing free access to COVID-19 vaccines for every adult living in the United States. For individuals who are underinsured, providers may submit claims for reimbursement for administering the COVID-19 vaccine through the COVID-19 Coverage Assistance Fund administered by HRSA after the claim to the individual’s health plan for payment has been denied or only partially paid. Information is available at https://www.hrsa.gov/covid19-coverage-assistance.

For individuals who are uninsured, providers may submit claims for reimbursement for administering the COVID-19 vaccine to individuals without insurance through the Provider Relief Fund, administered by HRSA. Information on the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program is available at https://www.hrsa.gov/CovidUninsuredClaim.

More information on Medicare payment for COVID-19 vaccine administration – including a list of billing codes, payment allowances and effective dates – is available at https://www.cms.gov/medicare/covid-19/medicare-covid-19-vaccine-shot-payment.

More information regarding the CDC COVID-19 Vaccination Program Provider Requirements and how the COVID-19 vaccine is provided through that program at no cost to recipients is available at https://www.cdc.gov/vaccines/covid-19/vaccination-provider-support.html.

Medicare Ambulance Relief Bill Introduced in House

Yesterday, Congresswoman Terri Sewell (D-AL) introduced the Protecting Access to Ground Ambulance Medical Services Act of 2021 (H.R. 2454). Congresswoman Sewell was joined by Congressmen Devin Nunes (R-CA), Peter Welch (D-VT) and Markwayne Mullin (R-OK) as primary cosponsors and leads on the legislation.

H.R. 2454 would extend the temporary Medicare ground ambulance increases of 2% urban, 3% rural and the super rural bonus payment for five years. The increases are currently scheduled to expire on December 31, 2022. The five-year extension would allow for the increases to remain in place during the two-year delay on ambulance data collection period due to the COVID-19 public health emergency.  It would also permit the cost collection program to move forward so that the statutorily mandated MedPAC analysis could be completed before the Congress would have to act to either further extend the add-ons or make them permanent through reforming the Medicare ambulance fee schedule.

The legislation would help address potential problems that rural zip codes in large urban counties could face as a result of the 2020 census data.  As we saw after the 2010 Census, the new Census data collection methodology resulted in geographical changes under the fee schedule that shifted rural ZIP codes to urban, despite there being no significant change in their population. The current definition using rural urban commuting areas (RUCA) in Goldsmith Modification areas would be modified to ensure ZIP codes with 1,000 people or less per square mile would remain rural. Ground ambulance service providers and suppliers could also petition the Centers for Medicare and Medicaid Services (CMS) to make the argument that a specific ZIP code should remain rural. It is vital that this provision be implemented before CMS makes changes from the 2020 Census data which will likely occur in 2023.

The AAA has been leading the effort on the legislation with the support of the Congressional Fire Services Institute, International Association of Fire Chiefs, International Association of Fire Fighters, National Association of EMTs and the National Volunteer Fire Council.

The AAA is working with champions of the effort in the Senate on introduction of a companion bill. We expect the bill to be introducing in the coming weeks.

The legislation is one of the policy issues being raised as part of EMS on the Hill Day and the AAA will be launching a Call To Action shortly requesting AAA members to ask their members of Congress to cosponsor the bill.

We greatly appreciate the leadership of Representatives Sewell, Nunes, Welch and Mullin on this vital issue.

CMS | 4/13 Webinar | HRSA COVID-19 Uninsured Program

From CMS on April 12, 2021

Upcoming Webinar for Providers on the HRSA COVID-19 Uninsured Program: Interested in learning more about the HRSA COVID-19 Uninsured Program? Participating providers are reimbursed at Medicare rates for testing, treating and administering COVID-19 vaccines to uninsured individuals.

Providers who have conducted COVID-19 testing to uninsured individuals, provided treatment for uninsured individuals with a COVID_19 diagnosis on or after February 4, 2020, or administered COVID-19 vaccines to uninsured individuals can begin the process to file claims for reimbursement. Providers can familiarize themselves with this process at https://www.hrsa.gov/coviduninsuredclaim, and learn more and file claims at https://coviduninsuredclaim.linkhealth.com/. Providers can also view Frequently Asked Questions about the program.

Join us on Tuesday April 13, 2021 at 2PM ET for an informational webinar.

Register Now

Feel free to share this with others who may be interested!

CMS | Sequestration Update | Temporary Claims Hold

From CMS on March 30, 2021

Temporary Claims Hold Pending Congressional Action to Extend 2% Sequester Reduction Suspension

In anticipation of possible Congressional action to extend the 2% sequester reduction suspension, we instructed the Medicare Administrative Contractors (MACs) to hold all claims with dates of service on or after April 1, 2021, for a short period without affecting providers’ cash flow. This will minimize the volume of claims the MACs must reprocess if Congress extends the suspension; the MACs will automatically reprocess any claims paid with the reduction applied if necessary.

Joint Letter on Sequestration Delay

On March 15, the AAA, IAFC, IAFF, NFVC, NAEMT, and the Congressional Fire Services Institute sent a letter to congressional leaders in support of legislation (H.R. 1868) to extend the current moratorium on the 2% Medicare sequestration cut. The moratorium is currently scheduled to expire on March 31 and H.R. 1868 would extend the moratorium until December 31. Below is a copy of the letter.

This week, the House passed House Resolution 233 with the rules for debate and consideration of H.R. 1868. Congressmen Schneider (D-IL) and McKinley (R-WV) introduced H.R. 315 and Senators Sheehan (D-NH) and Collins (R-ME) introduced S. 748 which would extend the moratorium through the end of the public health emergency.

March 16, 2021

The Honorable Nancy Pelosi Speaker
U.S. House of Representatives
Washington, DC 20515

The Honorable Kevin McCarthy Minority Leader
U.S. House of Representatives
Washington, DC 20515

The Honorable Charles Schumer Majority Leader
United States Senate
Washington, DC 20510

The Honorable Mitch McConnell Minority Leader
United States Senate
Washington, DC 20510

Dear Speaker Pelosi, Majority Leader Schumer, Minority Leader McConnell and Minority Leader McCarthy:

Thank you for your continued support of front-line medical workers throughout the COVID-19 pandemic. Our paramedics, emergency medical technicians (EMTs) and firefighters, as well as the organizations that they serve, take on substantial risk every day to treat, transport and test potential COVID-19 patients. We write today to express our deep concern with the impending 2% Medicare sequestration cut scheduled to take effect on April 1, 2021.

The American Ambulance Association (AAA), International Association of Fire Chiefs (IAFC), International Association of Fire Fighters (IAFF), National Association of Emergency Medical Technicians (NAEMT), National Volunteer Fire Council (NVFC) along with the Congressional Fire Services Institute (CFSI) represent the providers of vital emergency and non-emergency ground ambulance services and the paramedics, EMTs and firefighters who deliver the direct medical care and transport for every community across the United States. We have all experienced the strain on our services, and need financial assistance and support as we remain the frontline responders to our nation’s coronavirus patients. The sequestered cuts, if implemented, would further strain the provision of these critical services.

Our costs of operating have increased exponentially in response to COVID-19, as we maintain full readiness to combat the pandemic and continue to provide 24-hour vital non-COVID-19- related services. Our costs for personal protective equipment (PPE), overtime pay, and other expenses directly related to COVID-19 remain high. At a time when we are facing considerable economic strain due to the COVID-19 pandemic, we respectfully urge Congress take action before April 1, 2021 to extend the 2% Medicare sequestration moratorium. We would like to voice our strong support for bipartisan legislation, H.R. 1868, to prevent the 2% sequester cut.

Our organizations greatly appreciate both the financial support provided through congressionally enacted COVID-19 relief legislation, as well as the recognition of the dangers of providing these critical services on a daily basis. However, the impact of the pandemic on our resources and services remains and the implementation of additional Medicare cuts at this time would be harmful to our members.

We thank you in advance for your consideration and helping ensure that EMS agencies and personnel have the resources they need to continue to respond to the COVID-19 pandemic and the funding to maintain the short and long-term viability of our operations.

Sincerely,

American Ambulance Association

Congressional Fire Services Institute

International Association of Fire Chiefs

International Association of Fire Fighters

National Association of Emergency Medical Technicians

National Volunteer Fire Council

CMS Increases Medicare Payment for COVID-19 Vaccinations

CMS Increases Medicare Payment for COVID-19 Vaccinations

 

                                                                        By Brian S. Werfel, Esq.

On March 15, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that it would be increasing the Medicare payment amount for administrations of the COVID-19 vaccines.

The original Medicare reimbursement rate depended, in part, on whether the vaccine being administered required a two-dose regimen (as is the case for the Pfizer-Biontech and Moderna vaccines), or a single dose (Johnson & Johnson vaccine).  For vaccinations that require a two-dose regime, CMS initially paid: (1) $16.04 for the administration of the first dose and (2) $28.39 for the administration of the second dose.  For vaccines that require only a single dose, Medicare paid $28.39 for the administration of that single dose.

Effective for vaccinations administered on or after March 15, 2021, CMS has increased these payments to $40 per administration.  Thus, the total reimbursement for a vaccine requiring a single dose will be $40, while the total reimbursement for a vaccine requiring a two-dose regimen will be $80.

CMS Ambulance Open Door Forum Oct 22

From CMS on October 16

Open Door Participation Instructions:

October 22, 1:00–2:30 on ET

This call will be Conference Call Only.

To participate by phone:

Dial: 1-888-455-1397 & Reference Conference Passcode: 9375124

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: 1-866-448-2572; Conference Passcode: No Passcode needed

Instant Replay is an audio recording of this call that can be accessed by dialing 1-866-448-2572 and entering the Conference Passcode beginning 1 hours after the call has ended. The recording is available until October 24, 11:59PM ET.

The next CMS Ambulance Open Door Forum is scheduled for:

Date:  Thursday October 22, 2020

Start Time:  1:00pm-2:30pm PM Eastern Time (ET);

Please dial-in at least 15 minutes before call start time.

Conference Leaders: Jill Darling, Susanne Seagrave

**This Agenda is Subject to Change**

1. Opening Remarks

  • Acting Chair- Susanne Seagrave, Acting Director, Division of Data Analysis and Market-Based Pricing (Center for Medicare)
  • Moderator – Jill Darling (Office of Communications)

2. Announcements & Updates

3. 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.

 

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-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.

 

Newsmax | Will Trump Get Ambulance Services Needed Pay From Government?

By John Gizzi via Newsmax.com

Although President Donald Trump promised Newsmax earlier this month that he would “certainly look into it,” several ambulance professionals and their representatives have since told us they have seen none of the operating funds in question from the Department of Health and Human Services.

Continue Reading on Newsmax.com

Preliminary Calculation of 2020 Ambulance Inflation Update

Section 1834(l)(3)(B) of the Social Security Act mandates that the Medicare Ambulance Fee Schedule be updated each year to reflect inflation.  This update is referred to as the “Ambulance Inflation Factor” or “AIF”.

The AIF is calculated by measuring the increase in the consumer price index for all urban consumers (CPI-U) for the 12-month period ending with June of the previous year.  Starting in calendar year 2011, the change in the CPI-U is now reduced by a so-called “productivity adjustment”, which is equal to the 10-year moving average of changes in the economy-wide private nonfarm business multi-factor productivity index (MFP).  The MFP reduction may result in a negative AIF for any calendar year.  The resulting AIF is then added to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.

For the 12-month period ending in June 2020, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 0.646%.

Cautionary Note Regarding CPI-U.  Members should be advised that the BLS’ calculations of the CPI-U are preliminary, and may be subject to later adjustment.  Therefore, it is possible that these numbers may change.

CMS has yet to release its estimate for the MFP for calendar year 2021.  Since its inception, this number has fluctuated between 0.3% and 1.2%.  For calendar year 2020, the MFP was 0.7%.  Under normal circumstances, it would be reasonable to expect the 2021 MFP to be within a percentage point or two of the 2020 MFP.  However, the economic impact of the COVID-19 pandemic makes predictions on the MFP difficult at this point.

Accordingly, the AAA is not in a position to confidently project the 2021 Ambulance Inflation Factor at this point in time.  However, the relative low increase in the CPI-U strongly suggests that the 2021 Ambulance Inflation Factor will be significantly lower than last year’s increase of 0.9%.

The AAA will notify members once CMS issues a transmittal setting forth the official 2021 Ambulance Inflation Factor.

 

 

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HHS | Post-Payment Notice of Reporting Requirements

From HHS on July 20, 2020

General and Targeted Distribution Post-Payment Notice of Reporting Requirements

July 20, 2020

Purpose

The purpose of this notice is to inform Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing of future reporting requirements. Detailed instructions regarding these reports will be released by August 17, 2020.

Overview

Congress appropriated funding to reimburse eligible health care providers for health care related expenses or lost revenues attributable to coronavirus. The Health Resources and Services Administration (HRSA) is administering the distribution of payments under the PRF program, funded through appropriations in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) and the Paycheck Protection Program and Health Care Enhancement Act (P.L. 116-139). Each recipient of a payment from the PRF that used any part of that payment agreed to a set of Terms and Conditions (T&Cs) which, among other obligations, require each recipient to submit reports to the Department of Health and Human Services (HHS). The reports shall be in such form, with such content, as specified by the Secretary of HHS in future program instructions directed to all recipients. HHS will be releasing detailed reporting instructions by August 17, 2020.

These reporting instructions will provide directions on reporting obligations applicable to any provider that received a payment from the following CARES Act/PRF distributions:

General Distributions:
  • Initial Medicare Distribution
  • Additional Medicare Distribution
  •  Medicaid, Dental & CHIP Distribution
Targeted Distributions:
  • High Impact Area Distribution
  •  Rural Distribution
  •  Skilled Nursing Facilities Distribution
  •  Indian Health Service Distribution
  •  Safety Net Hospital Distribution

The reports will allow providers to demonstrate compliance with the T&Cs, including use of funds for allowable purposes, for each PRF payment. HRSA plans to provide recipients with Question and Answer (Q&A) Sessions via Webinar in advance of the submission deadline. Additional details will follow regarding the Q&A Sessions.

Notice on Timing of Reports

The reporting system will become available to recipients for reporting on October 1, 2020.

  • All recipients must report within 45 days of the end of calendar year 2020 on their expenditures through the period ending December 31, 2020.
  •  Recipients who have expended funds in full prior to December 31, 2020 may submit a single final report at any time during the window that begins October 1, 2020, but no later than February 15, 2021.
  •  Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.
  •  Detailed PRF reporting instructions and a data collection template with the necessary data elements will be available through the HRSA website by August 17, 2020.

 

CMS Announces Resumption of Program Integrity Functions

On July 7, 2020, CMS updated its Coronavirus Disease 2019 (COVID-19) Provider Burden Relief Frequently Asked Questions (FAQs).  As part of this update, CMS indicated that it would resume several program integrity functions, starting on August 3, 2020.  This includes pre-payment and post-payment medical reviews by its Medicare Administrative Contractors (MACs), the Supplemental Medical Review Contractor (SMRC), and the Recovery Audit Contractors (RACs).  This also includes the resumption of the Prior Authorization Model for scheduled, repetitive non-emergency ambulance transports.  These programs had been suspended by CMS in March in response to the COVID-19 pandemic.

Resumption of Medicare Fee-For-Service Medical Reviews

 CMS suspended most Medicare FFS medical reviews on March 30, 2020.  This included pre-payment medical reviews conducted by its MACs under the Targeted Probe and Educate program, as well as post-payment reviews by its MACs, the SMRC, and the RACs.  CMS indicated that, given the importance of medical review activities to CMS’ program integrity efforts, it expects to discontinue its “enforcement discretion” beginning on August 3, 2020.

CMS indicated that providers selected for review should discuss any COVID-related hardships that might affect the provider’s ability to respond to the audit in a timely fashion with their contractor.

CMS further indicated that its contractors will be required to consider any waivers and flexibilities in place at the time of the dates of service of claims selected for future review.

Resumption of Prior Authorization Model

 Under the Repetitive, Scheduled, Non-Emergent Ambulance Transport Prior Authorization Model, ground ambulance providers in affected states are required to seek and obtain prior authorization for the transportation of repetitive patients beyond the third round-trip in a 30-day period.  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.

On March 29, 2020, CMS suspended certain claims processing requirements under the Prior Authorization Model.  During this “pause,” claims for repetitive, scheduled, non-emergency transports were not be stopped for pre-payment review to the extent prior authorization had not been requested prior to the fourth round trip in a 30-day period.  However, CMS continued to permit ambulance providers to submit prior authorization requests to their MACs.

CMS indicated that full model operations and pre-payment review would resume for repetitive, scheduled non-emergent ambulance transportation submitted in the model states on or after August 3, 2020.  CMS stated that the MACs will be required to conduct postpayment review on claims that were subject to the model, and which were submitted and paid during the pause.  CMS further indicated that it would work with the affected providers to develop a schedule for postpayment reviews that does not significantly increase the burden on providers.

CMS stated that claims that received a provision affirmation prior authorization review decision, and which were submitted with an affirmed Unique Tracking Number (UTN) will continue to be excluded from most future medical review.

Stat | Treatment in Place

From Stat on June 29, 2020 by Hanan Cohen of Empress EMS and Patient Care EMS Solutions

Medicare shouldn’t make ground ambulance services take a financial hit for providing at-home care

Ever since the coronavirus pandemic began sweeping across the U.S., ambulance crews have been treating some patients at home rather than risking a hospital surge — and aren’t getting paid for it. At a time when ambulance services are on the frontlines of care, not just transport, Medicare is treating ambulances like expensive taxicabs.

Treating people in place — at the scene of a medical emergency, which can include the home, a long-term care facility, or other location — has become the expected standard of care, especially during the pandemic. Some states even mandate it. But the Centers for Medicare and Medicaid Services, which oversees Medicare payments, refuses to pay companies for the cost of providing medically necessary health care services if the patient is not transported to a hospital or other designated destination.

As a result, ground ambulance organizations that are fighting the Covid-19 pandemic on the frontlines by treating people with everything from low blood sugar to dehydration are taking a massive financial hit. And it’s coming at the worst time.

Continue reading►

HHS Posts FAQ on Healthcare COVID-19 Relief Fund

Earlier today, the Department of Health and Human Services (HHS) posted a revised set of frequently asked questions (FAQs) regarding the terms and details of payments distributed under the Public Health and Social Services Emergency Fund to Medicare providers including ground ambulance service providers and suppliers. The updated FAQs cover a range of topics regarding the acceptance of funds, revenue data submission and eligibility criteria.

Download FAQ

CMS Modifies the Cost Data Collection System Year 1 Data Collection

CMS has issued a blanket waiver modifying the data collection period for the ground ambulance services that were selected to report in Year 1.  Under the current law, these organizations would have been required to collect data beginning January 1, 2020, and through December 31, 2020.  The waiver allows these organizations to select a new continuous 12-month data collection period that begins between January 1, 2021 and ends December 31, 2021.  This modification means that such organizations will collect and report data during the same time period as the ground organizations that CMS will select for Year 2 of the cost collection program.

From the summary of the waiver, it appears that organizations will have the choice of submitting data in Year 1 or Year 2.  CMS has not moved the timeline for any other data collection year, so there is the potential for a substantial number of organizations to report in Year 2, which would increase the amount of data available.

The AAA has supported the data collection system to make sure that CMS and the Congress have valid and reliable data to support maintaining the geographic add-ons to the Medicare Ambulance Fee Schedule and to support efforts to address the chronic underfunding of the Medicare Ambulance Fee Schedule.

The complete FAQ is below and also available at: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf (on page 29).

“CMS is modifying the data collection period and data reporting period, as defined at 42 CFR § 414.626(a), for ground ambulance organizations (as defined at 42 CFR § 414.605) that were selected by CMS under 42 CFR § 414.626(c) to collect data beginning between January 1, 2020 and December 31, 2020 (year 1) for purposes of complying with the data reporting requirements described at 42 CFR § 414.626. Under this modification, these ground ambulance organizations can select a new continuous 12-month data collection period that begins between January 1, 2021 and December 31, 2021, collect data necessary to complete the Medicare Ground Ambulance Data Collection Instrument during their selected data collection period, and submit a completed Medicare Ground Ambulance Data Collection Instrument 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 and 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 42 CFR § 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 42 CFR § 414.626.”

House Vote Scheduled today on HEROES Act

The U.S. House of Representatives is scheduled to vote later today on the Health and Economic Recovery Omnibus Emergency Solutions Act “HEROES Act” (H.R. 6800). The HEROES Act is the House Democratic proposal for the latest legislative effort on economic relief related to COVID-19. The House is expected to pass the HEROES Act along party lines with the Senate developing its own legislative proposal with consideration in the coming weeks.

The HEROES Act contains numerous provisions of interest to ground ambulance service providers and suppliers. For a comprehensive summary of those provisions, please click HERE.

Here are a few of the highlights:

$100 Billion for Health Care Fund

  • $100 billion in additional funding for the Public Health and Social Services Emergency Fund. This is the Fund under which ground ambulance service providers and suppliers have received direct payments to partially offset lost revenue as well as eligibility for grant funds to cover the cost of treating uninsured presumptive and actual COVID-19 patients. The bill would also set forth a methodology for the distribution of the new funds and all previously unallocated funds, based on the lost revenue and expenses of a provider or supplier. The AAA continues to advocate for a program under the Fund specifically for ground ambulance services.

Employee Retention Tax Credit Improvements

  • Increases the retention credit from 50% to 80% and the wage cap from $10,000 to $15,000 per quarter. The bill would also change the definition of a large employer from organizations with over 100 employees to those with over 1,500 employees. The Employee Retention Tax Credit is intended for companies not eligible for the Paycheck Protection Program and allows employers to offset employment taxes, with any excess treated as refundable tax credits.

Payroll Protection Program

  • Eliminates the limitation for employers to take advantage of the payroll tax deferral period to the extent they qualified for loan forgiveness under the Paycheck Protection Program or the U.S. Treasury Program Management Authority.

$500 Tax Credit for First Responders and Frontline Employees

  • Provides a $500 above the line deduction for 2020 for the uniforms, supplies, and equipment of governmental and non-governmental first responders and COVID19 frontline employees.

The AAA has already turned its sights on the Senate as we continue to advocate for ground ambulance service providers and suppliers in our vital role as frontline medical responders in combating COVID-19.