Issue Impacting Medicare Claims for Patients in a Part A SNF Stay
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orFrom FAIR Health in February 2022
“Currently, no federal law protects consumers against “surprise” bills from out-of-network ground ambulance providers. Some state and local governments regulate ground ambulance surprise billing practices; however, such laws may not apply to all health plans or ambulance providers in an area. Because of the substantial policy interest in ground ambulance services, FAIR Health drew on its vast database of private healthcare claims to illuminate multiple aspects of such services across the nation, including utilization, costs, age, gender, diagnoses and differences across states.”
Yesterday, the American Ambulance Association Board of Directors approved the Association’s advocacy priorities for 2022. Our key initiatives reflect the challenges we face this year, including short-sighted threats to EMS balance billing, a worsening workforce shortage, the expiration of the temporary Medicare increases, and potential sequestration cuts.
We also continue to fight for you as you care for people first on the frontlines of the COVID-19 pandemic. We will sustain our efforts at securing additional funding for ground ambulance services to help address the increased costs of providing medical care and transport during the Public Health Emergency.
To achieve our collective goals, the AAA Board will need to mobilize the full voice of influence of the EMS community this year. If you have not already sent an email using the AAA advocacy system to your members of Congress, please do so today!
Staff will be reaching out to you at key points later in the year about letter writing for specific individual policy requests. But it is important that they hear from you now on all the top issues for ground ambulance services. They are:
With the persistent shortage of ground ambulance service field personnel raising to a crisis level with the COVID-19 pandemic, the AAA moved the issue to a top policy priority. The AAA is currently working with key Congressional Committees of jurisdiction to hold hearings on the EMS workforce shortage. We are also developing legislation to specifically target increasing access for ground ambulance service organizations to federal programs and funding for the retention and training of health care personnel.
The AAA successfully educated the Congress on the role of local government oversight and other unique characteristics of providing ground ambulance service organizations. As a result, the Congress directed the establishment of a Ground Ambulance and Balance Billing Advisory Committee to address the issue. The Committee is in the process of being formed and then has 180 days in which to make recommendations to the Congress. The AAA will be involved with the Committee and advocating that the Congress implement policies that meet the needs of our members.
The AAA is advocating for additional financial assistance for ground ambulance service organizations to help address the increased costs of labor and other higher costs associated with providing health care during the COVID-19 pandemic.
The temporary Medicare ambulance increases of 2% urban, 3% rural and the super rural bonus payment expire at the end of the year. The AAA will continue to push for passage of the provisions of the Preserving Access to Ground Ambulance Medical Services Act (S. 2037, H.R. 2454) before the provisions expire as well as for the adoption of language to ensure truly rural areas remain rural following changes to geographical designations based on the 2020 census.
The Congress delayed the additional 4% sequestration cut for only one yea. The AAA is working with other EMS and health care provider and supplier groups to permanently prevent the cut from going into effect as well as further extending the moratorium on the long-standing 2% cut.
With the 2-year delay of ambulance data collection due to the pandemic, the Medicare Payment Advisory Committee (MedPAC) will have little to no data to analyze in March 2023 in which to make recommendations to the Congress on Medicare ambulance payment policy and rates. The AAA is asking the Congress to push back the date of the MedPAC report and also expand the modified data collection timeline of two years to the intended four years.
On behalf of my fellow board members, I again thank you for your continued membership and participation. We look forward to serving you for many years to come.
Should you have any questions regarding our advocacy priorities, please contact AAA Senior Vice President of Government Affairs Tristan North at tnorth@ambulance.org.
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orThe next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, December 9, 2021
Start Time: 2:00pm-3:00pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
Announcements & Updates
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:
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: 1-800-856-2271; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-800-856-2271 and entering the Conference Passcode beginning 1 hours after the call has ended. The recording is available until December 11, 2021, 11:59PM ET.
For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/
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-
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.
From CMS
Medicare Ground Ambulance Data Collection System Webinar: Question and Answer (Q&A) Session Tuesday, December 14, 2021 | 2:00 PM – 3:00 PM ET
To register for this CMS Zoom webinar:
https://cms.zoomgov.com/webinar/register/WN_Jy_wpLZLQnuNu5vv_5Dbyw
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 December 14, 2021 at 2:00 pm. Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “December 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 using the “Q&A” button at the bottom of your Zoom screen. 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 list of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 PFS Final Rule, the CY 2020 PFS final rule, and the Bipartisan Budget Act of 2018.
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orRecorded 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.
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
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:
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@
More Information:
From CMS
Medicare Ground Ambulance Data Collection System: Question 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.
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.
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
**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
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.
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.
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.
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orWebinar 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!