From CMS on October 16
October 22, 1:00–2:30 on ET
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The next CMS Ambulance Open Door Forum is scheduled for:
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**This Agenda is Subject to Change**
**DATE IS SUBJECT TO CHANGE**
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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.
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.
American Ambulance Association Medicare Consultant Brian Werfel, Esq provides a brief update on the HHS COVID-19 Provider Relief Fund.
July 20, 2020
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.
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:
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.
The reporting system will become available to recipients for reporting on October 1, 2020.
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.
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.
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.
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.”
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
Employee Retention Tax Credit Improvements
Payroll Protection Program
$500 Tax Credit for First Responders and 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.
On May 1, 2020, CMS updated its “COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing.” The full document can be viewed by clicking here.
In the updated FAQ, CMS answers three important questions related to ambulance vehicle and staffing requirements:
By Kathy Lester, J.D., M.P.H
Ground ambulance services and the organizations who provide them play a critically important role in helping America combat the coronavirus/COVID-19 pandemic. The members of the American Ambulance Association (AAA) are on the frontlines and often the first health care providers to interact with patients who suspect they are infected with the virus. At the same time, ground ambulance EMTs and paramedics continue to care for patients who have other medical emergency and are now frightened about seeking health care outside their homes.
The Medicare program has recognized these new realities and has provided important flexibility during the public health emergency that eliminate barriers to providing the necessary care. For example, Medicare has expanded the destinations where ground ambulance can transport patients and suspended some paperwork requirements (such as the signature requirements on the PCS form) and audits during the public health emergency. The AAA supports these modifications and has recommended two others: (1) that patients who require medical isolation can get to/from essential medical appointments; and (2) that Medicare pays for ground ambulance health care services provided without transportation to assist in reducing hospital surge and allow patients to remain quarantined in their homes when necessary.
With the additional flexibility provided by Medicare comes additional responsibility. As America’s health care safety net providers, ground ambulance service organizations are also committed to protect against fraud and abuse in the health care system. Our members are equally committed to providing services in an ethical and responsible manner. We recognize that oversight has diminished to ensure that patients get the right care at the right place at the right time. The AAA encourages all of our members and others in the health care community to use their best judgment and rely upon the relaxed guidance only when necessary. These guidance documents are not an opportunity to justify fraudulent or abusive behaviors.
The Department of Health and Human Services recently updated its guidance on the disbursement of provider relief funds under the CARES Act for the testing and treatment of the uninsured. Previously, HHS indicated that this allocation was only available for the reimbursement of emergency and non-emergency ground ambulance transportation. However, in its most recent update, HHS has removed the restriction that limited participation to ground ambulance providers and suppliers. The new guidance indicates that the relief funds are now available for all emergency ambulance transportation and non-emergency patient transfers via ambulance.
Thus, it appears that air and water ambulance providers and suppliers are now eligible to receive funding for the treatment of COVID-19 patients.
Is there anything my air or water ambulance organization needs to do to claim reimbursement for treatment of uninsured COVID patients?
Yes. In order to be eligible for payments for the treatment of uninsured COVID patients, you must enroll as a participant in the program. Enrollment must be done through an online portal that can be accessed at: http://www.coviduninsuredclaim.hrsa.gov.
Once my organization enrolls, when can we start submitting claims for reimbursement for treatment of uninsured COVID patients?
HHS has indicated that it will begin to accept claims for reimbursement for treatment of the uninsured on May 6, 2020.
FUNDING FOR TREATMENT OF UNINSURED COVID PATIENTS IS SUBJECTED TO AVAILABLE FUNDING, AND IS THEREFORE ON A FIRST-COME, FIRST-SERVED BASIS. IT IS EXPECTED THAT THESE FUNDS WILL BE EXHAUSTED IN FAIRLY SHORT ORDER.
FOR IMMEDIATE RELEASE
April 26, 2020
CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program
Today, the Centers for Medicare & Medicaid Services (CMS) announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately. The agency made this announcement following the successful payment of over $100 billion to healthcare providers and suppliers through these programs and in light of the $175 billion recently appropriated for healthcare provider relief payments.
CMS had expanded these temporary loan programs to ensure providers and suppliers had the resources needed to combat the beginning stages of the 2019 Novel Coronavirus (COVID-19). Funding will continue to be available to hospitals and other healthcare providers on the front lines of the coronavirus response primarily from the Provider Relief Fund. The Accelerated and Advance Payment (AAP) Programs are typically used to give providers emergency funding and address cash flow issues for providers and suppliers when there is disruption in claims submission or claims processing, including during a public health emergency or Presidentially-declared disaster.
Since expanding the AAP programs on March 28, 2020, CMS approved over 21,000 applications totaling $59.6 billion in payments to Part A providers, which includes hospitals. For Part B suppliers, including doctors, non-physician practitioners and durable medical equipment suppliers, CMS approved almost 24,000 applications advancing $40.4 billion in payments. The AAP programs are not a grant, and providers and suppliers are typically required to pay back the funding within one year, or less, depending on provider or supplier type. Beginning today, CMS will not be accepting any new applications for the Advance Payment Program, and CMS will be reevaluating all pending and new applications for Accelerated Payments in light of historical direct payments made available through the Department of Health & Human Services’ (HHS) Provider Relief Fund.
Significant additional funding will continue to be available to hospitals and other healthcare providers through other programs. Congress appropriated $100 billion in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (PL 116-136) and $75 billion through the Paycheck Protection Program and Health Care Enhancement Act (PL 116-139) for healthcare providers. HHS is distributing this money through the Provider Relief Fund, and these payments do not need to be repaid.
The CARES Act Provider Relief Fund is being administered through HHS and has already released $30 billion to providers, and is in the process of releasing an additional $20 billion, with more funding anticipated to be released soon. This funding will be used to support healthcare-related expenses or lost revenue attributable to the COVID-19 pandemic and to ensure uninsured Americans can get treatment for COVID-19.
For more information on the CARES Act Provider Relief Fund and how to apply, visit hhs.gov/providerrelief
For an updated fact sheet on the Accelerated and Advance Payment Programs, visit: https://www.cms.gov/files/
Updated April 24, 2020 at 9:40 pm | Register for AAA’s 4/27 webinar on this topic►
At 5 p.m. on Friday, April 24, 2020, the Department of Health and Human Services opened the online portal that health care providers and suppliers must use to submit their revenue information. This is a requirement to access the second $20 billion tranche of general allocation funding. Access the online portal►
In order to provide the required information, you will need the following information/documentation:
The portal will ask a series of questions to verify your identity and the identity of your organization. These include providing your TIN and the last six digits of the bank account to which the original tranche of relief funding was provided.
After completing the verification process, you will be asked to complete an attestation that you received the initial tranche of relief funding.
You will then be prompted to complete a short questionnaire that is used to apply for additional funding. The steps for completing that questionnaire are as follows:
AAA is aware of an issue that may affect governmental EMS organizations. Specifically, those governmental agencies that do not file federal tax returns may not be able to complete the final stage of the application, which asks you to upload a copy of your most recent tax return. The AAA has reached out to HHS to request guidance on how governmental organizations should complete the form. We will update our members as soon as we know anything different. Register for our May 4 COVID-19 Financial Resources for Governmental Providers webinar►
HHS indicated that it will allocate an undisclosed portion of the $29.6 billion in otherwise unallocated relief funding to reimburse healthcare providers and suppliers for COVID-related treatment of the uninsured. Please note that this allocation is only available for the reimbursement of emergency and non-emergency ground ambulance transports. Reimbursement will be available for COVID-related care furnished with dates of service on or after February 4, 2020. Payments will be made at the Medicare rates, subject to available funding. As a condition to receipt of funding, you must agree to accept HHS’ payment as payment-in-full, i.e., you may not balance bill the uninsured patient.
Yes. In order to be eligible for payments for the treatment of uninsured COVID patients, must enroll as a participant in the program. Enrollment must be done through an online portal that will open starting on April 27, 2020. Once open, the portal can be accessed at http://www.coviduninsuredclaim.hrsa.gov.
HHS has indicated that it will begin to accept claims for reimbursement for the treatment of the uninsured at some point in early May 2020.
FUNDING FOR TREATMENT OF UNINSURED COVID PATIENTS IS SUBJECTED TO AVAILABLE FUNDING, AND IS THEREFORE ON A FIRST-COME, FIRST-SERVED BASIS. IT IS EXPECTED THAT THESE FUNDS WILL BE EXHAUSTED IN FAIRLY SHORT ORDER.
The AAA strongly recommends that all members complete their enrollment form as soon as reasonably practicable, so that you are in a position to submit claims as soon as the claim submission window opens.
HHS Announces Plans for Distribution of Remaining CARES Act Provider Relief Funding
By Brian S. Werfel, Esq.
March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). As part of that Act, Congress allocated $100 billion to the creation of a “CARES Act Provider Relief Fund,” which will be used to support hospitals and other healthcare providers on the front lines of the nation’s coronavirus response. These funds will be used to fund healthcare-related expenses or to offset lost revenue attributable to COVID-10. These funds will also be used to ensure that uninsured Americans have access to testing a treatment for COVID-19. Collectively, this funding is referred to as the “CARES Act Provider Relief Fund.”
The Department of Health and Human Services (HHS) began the disbursement of the first $30 billion tranche of the CARES Act Provider Relief Funding on April 10, 2020, with full disbursement of this tranche being completed by April 17, 2020. The American Ambulance Association has issued a Frequently Asked Question that provides additional details on how the payments under this first tranche were calculated, as well as the terms and conditions that are applicable to this disbursement.
On April 22, 2020, HHS announced its plans for the disbursement of the remaining $70 billion in CARES Act Provider Relief Funding. These monies will be distributed using four broad categories:
Upcoming Important Dates
To participate in these future funding tranches, AAA Members will need to keep the following dates in mind:
Thank you to PEW Stateline journalist Michael Ollove for taking the time to learn about EMS economics from AAA Payment Reform Chair Asbel Montes and Professional Ambulance Association of Wisconsin President Chris Anderson.
Stay-at-home orders have paused many activities that resulted in emergency calls, such as traffic accidents and shootings, said Chris Anderson, director of operations for Bell Ambulance in Wisconsin. As for non-emergency transportation, many people want to avoid health facilities now if they can, he said.
Asbel Montes, a senior vice president with Acadian Companies, a Louisiana-based firm operating 500 ambulances in Louisiana, Mississippi, Tennessee and Texas, said emergency calls have dropped by 30% and non-emergency calls by 70%.