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It’s Time for EMS to Apply for HHS Provider Relief Fund Tranche 4!

Recorded October 8, 2021 | Free to All | Speaker: Asbel Montes

The deadline for Provider Relief Fund (PRF) applications is 11:59 PM October 26, 2021. If your EMS agency has not yet applied for funds, the American Ambulance Association strongly encourages you to do so! We are happy to answer member questions, just email hello@ambulance.org. Remember, Amber cost data collection software (www.emsamber.com) access is included with your AAA membership and has a PRF module to help you with your application. If you are an AAA member and need help accessing Amber, email shilker@ambulance.org. HRSA is also hosting a technical assistance webinar for PRF applications on October 13, 2021.

CMS | Medicare Ground Ambulance Data Collection Webinars October 7 & 12

From CMS on October 4, 2021

Dear Ground Ambulance Providers and Suppliers,

Please attend our October 7 webinar and October 12 Q&A session to learn about the Medicare Ground Ambulance Data Collection System. Both events will use Zoom. Starting January 1, 2023, selected ground ambulance organizations are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10% payment reduction.

Medicare Ground Ambulance Data Collection System Webinar: Labor Costs – October 7

Thursday, October 7 from 2­­­­­­­­­­-3pm ET

Register for this Zoom webinar.

During this webinar, CMS will walk through the Labor Cost section of the Medicare Ground Ambulance Data Collection Instrument (section 7). The presentation includes examples to help different types of ground ambulance organizations understand how to collect and report data for their paid and volunteer staff.

A Q&A session will follow this presentation. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 7 Labor Cost Webinar” in the subject line.

More information:

 

Medicare Ground Ambulance Data Collection System: Q&A Session – October 12

Tuesday, October 12 from 2-3pm ET

Register for the session.

Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 12 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.

More Information:

TODAY | CMS Cost Data Collection System Q&A Session

CMS Medicare Ground Ambulance Data Collection Q&A Session

Tuesday, September 14 from 2-3 pm ET

CMS is hosting a Q&A session about the Medicare Ground Ambulance Data Collection System tomorrow at 2:00pm Eastern.

Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “September 14 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.

More Information:

Register for this session

 

CMS Webinar | Cost Collection Q&A

From CMS

Medicare Ground Ambulance Data Collection SystemQuestion and Answer Session on September 14, 2021 2:00 PM – 3:00 PM ET.

To participate in the Q&A session, you must register for the session at: https://cms.zoomgov.com/webinar/register/WN_tuyiGdvORRiTXbmPaTQ1zg.

After registering, you will receive a confirmation email containing information about joining the webinar.

Do you have questions about the Medicare Ground Ambulance Data Collection System? We are holding a live Q&A session on September 14, 2021 at 2:00 pm.  Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “September 14 Q&A” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions in the “chat” box.  In addition, we will update documents on our Ambulances Services Center webpage with answers to common questions from this session.  For more information, including the lists of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf, and the CY 2020 Physician Fee Schedule final rule.

CMS Webinar | Cost Collection Instrument Walk-Through

From CMS

Medicare Ground Ambulance Data Collection System Webinar: Instrument Walkthrough

Thursday, August 26, 2021 from 2:00 PM-3:30 PM ET.

To register for this webinar: https://cms.zoomgov.com/webinar/register/WN_S0aGs_TWTpWRBWF5hDAf3Q.

After registering, you will receive a confirmation email containing information about joining the webinar.

The slide presentation is available here. (PDF)

During this call, CMS will walk through the Medicare Ground Ambulance Data Collection Instrument section-by-section, focusing on select instructions, data collection guidelines, and common questions and answers. The webinar will also highlight proposed changes to the instrument in the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf.

A question-and-answer session will follow this presentation. You may send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “August 26 Instrument Webinar” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions in the “chat” box.

For more information, including ground ambulance organizations that must report, see the Ambulances Services Center webpage, CY 2020 Physician Fee Schedule final rule, and Bipartisan Budget Act of 2018.

CMS Open Door Forum | Medicare Ground Ambulance Data Collection System

August 12, 2021 Ambulance Open Door Forum

August 12, 2021 | 14:00–15:30 ET

Slide presentation on the Overview of the Medicare Ground Ambulance Data Collection System (PDF) is now available.

The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, August 12, 2021
Start Time: 2:00pm-3:30pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham

Agenda

**This Agenda is Subject to Change**

I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market-based Pricing
Moderator – Jill Darling (Office of Communications)

II. Announcements & Updates

  • Emergency Triage, Treat, and Transport (ET3) Model Update
    • ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
      • ET3Model@cms.hhs.gov for inquiries
      • ET3 Model Listserv for Model updates: https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12521

 

Overview of the Medicare Ground Ambulance Data Collection
System
 A copy of the presentation will be available on the
Ambulances Services Center website under
Spotlights: https://www.cms.gov/Center/ProviderType/Ambulances-Services-Center
III. 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.

Open Door Participation Instructions

This call will be Conference Call Only.

To participate by phone:
August 12, 2021 | 14:00–15:30 ET | Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
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

1-866-470-7051; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
866-470-7051 and entering the Conference Passcode beginning 1 hours after the
call has ended. The recording is available until August 14, 2021, 11:59PM ET.

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-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

 

EMS Balance Billing Quick Take—July 7, 2021

Webinar July 7, 2021 | 13:00–13:30 ET | Free to AAA Members
Speakers: Kathy Lester, Esq. & Asbel Montes

On July 1, CMS issued a proposed rule on Surprise Billing which applies to those providers and physicians identified in the No Surprises Act. This statute subjected ground ambulance suppliers to an HHS Advisory Committee process prior to any rulemaking addressing these services.

The consultants and staff of the American Ambulance Association are doing a deep dive into the 400+ page rule and evaluating its nuances. We continue to understand from our conversations that ground ambulances are not included and instead are subjected to the Advisory Committee.

The American Ambulance Association will soon provide a summary to members, and will address any confusion with the Administration. Join AAA for a quick take live webinar on July 7 at 13:00 ET to learn more!

Register Now

 

CMS | New Medicaid and CHIP Enrollment Snapshot

FOR IMMEDIATE RELEASE
June 21, 2021

Contact: CMS Media Relations
CMS Media Inquiries

New Medicaid and CHIP Enrollment Snapshot Shows Almost 10 million Americans Enrolled in Coverage During the COVID-19 Public Health Emergency

Report Shows Record Medicaid Enrollment and Highlights the Program’s Importance in Preserving Coverage for Millions of Children and Adults Throughout the United States

The Centers for Medicare & Medicaid Services (CMS) released a new Enrollment Trends Snapshot report today showing a record high, over 80 million individuals have health coverage through Medicaid and the Children’s Health Insurance Program (CHIP).  Nearly 9.9 million individuals, a 13.9% increase, enrolled in coverage between February 2020, the month before the public health emergency (PHE) was declared, and January 2021.

Among the 50 states and the District of Columbia, a total of 80,543,351 people were enrolled and receiving full benefits from the Medicaid and CHIP programs by the end of January 2021. In the 50 states that reported total Medicaid child and CHIP enrollment data for January 2021, over 38.3 million children were enrolled in Medicaid and CHIP combined, approximately 50% of the total Medicaid and CHIP enrollment. These numbers highlight the essential role the Medicaid and CHIP programs play in providing quality and needed coverage for millions of vulnerable children and adults. In fact, both programs serve as the largest single source of health coverage in the country.

“The Biden-Harris administration is using every lever to ensure any American needing access to quality health coverage receives it. Now more than ever, people need the peace of mind of knowing that they have health coverage,” said HHS Secretary Xavier Becerra. “This report reminds us what a critical program and rock Medicaid continues to be in giving tens of millions of children and adults access to care. This pandemic taught us that now more than ever, we must work to strengthen Medicaid and make it available whenever and wherever it’s needed using the unprecedented investments Congress provided.”

The increase in total Medicaid and CHIP enrollment is largely attributed to the impact of the COVID-19 PHE, in particular, enactment of section 6008 of the Families First Coronavirus Response Act (FFCRA). FFCRA provides states with a temporary 6.2% payment increase in Federal Medical Assistance Percentage (FMAP) funding.  States qualify for this enhanced funding by adhering to the Maintenance of Effort requirement, which ensures eligible people enrolled in Medicaid stay enrolled and covered during the PHE.

“Medicaid and CHIP serve as a much-needed lifeline for millions of people throughout this country. The increase we are seeing is exactly how Medicaid works: the program steps in to support people and their families when times are tough,” said CMS Administrator Chiquita Brooks-LaSure. “For the parents that may have lost a job or had another life change during the pandemic, having access to coverage for themselves and their kids is life-changing. CMS is committed to ensuring our nation’s marginalized communities and low-income families have the coverage they need.”

To assist states and territories in their response to the COVID-19 PHE, CMS developed numerous strategies to support Medicaid and CHIP programs in times of crisis, including granting states more flexibility in their Medicaid and CHIP operations. Today’s data release also reflects a range of indicators related to key application, eligibility, and enrollment processes from within state Medicaid and CHIP agencies.

The Snapshot is a product of the Centers for Medicare and Medicaid CHIP Services (CMCS) Medicaid and CHIP Coverage Learning Collaborative (MACLC), which monitors Medicaid and CHIP enrollment trends, primarily using the CMS Performance Indicator (PI) data reported to CMS by state Medicaid and CHIP agencies. PI data reflects key Medicaid and CHIP business processes- including applications, renewals, eligibility determinations, and enrollment.

The Enrollment Trends Snapshot, which is released monthly, is available here:  https://www.medicaid.gov/medicaid/program-information/medicaid-chip-enrollment-data/medicaid-and-chip-enrollment-trend-snapshot/index.html

The complete dataset, including data from January 2021, is available on data.Medicaid.gov.

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.

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.

Bipartisan, Bicameral Members of Congress Reach Agreement on “Surprise” Billing Legislation

It appears that members of Congress on the House Ways & Means, Energy & Commerce, and Education & Labor Committees along with the Senate Health, Education, Labor, & Pensions Committee have reached a compromise agreement that will allow “surprise” billing legislation to be considered for passage before the end of the year.  While the details of the legislation have yet to be unveiled, the American Ambulance Association has learned that it is likely to include provisions related to ground ambulance service and air ambulance service providers and suppliers.

Earlier legislation moved forward by the House Education & Labor Committee included a requirement for the Administration to create a Federal Advisory Committee to review ways to increase transparency around fees and charges for ground ambulance services and to better inform consumers about their treatment options.  We believe that this language will be included in the compromise, but that there may be an opportunity to suggest modifications to make it more balanced and fairer in terms of the charge of the Committee and the types of individuals and organizations who will be selected to participate on it.  The AAA is recommending that the Advisory Committee have at least a year to study and report on issues related to balance billing by ground ambulance service providers and suppliers, including the role of local and state governments in EMS systems amongst other considerations.  It is also important that the Committee members include representatives from all types, sizes, and geographical areas of ground ambulance service providers and suppliers, as well as state EMS officials, and paramedics and EMTs.

It is likely that if the congressional leadership agree to move this legislation forward, it would be attached to the end of the year packages that may also include COVID-19 relief, Medicare extenders, and the annual spending bills.

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.

 

 

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.

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