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Tag: 2017

2018 National and State-Specific Medicare Data

The American Ambulance Association is pleased to announce the publication of its 2018 Medicare Payment Data Report. This report is based on the “Early Edition” of the 2018 Part B National Summary Data File (previously known as the Bess Report). The report consists of an overview of total Medicare spending nationwide, and then a separate breakdown of Medicare spending in each of the 50 states, the District of Columbia, and the various other U.S. Territories.

For each jurisdiction, the report contains two charts: the first reflects data for all ambulance services, with the second limited to dialysis transports. Each chart is further broken down by HCPCS code. The charts provide information on the total number of allows services and the total Medicare payments for CYs 2017 and 2018. Percentage changes will allow members to view payment trends over the past year.

2018 National & State-Specific Medicare Data

Questions? Contact Brian Werfel at bwerfel@aol.com.

 

CMS SNF Edits Go Into Effect – April 1, 2019

CMS Set to Implement New Common Working File Edits to Identify Ambulance Services Provided in Connection with Outpatient Hospital Services that should be bundled to the SNF under Consolidated Billing

On November 2, 2018, the Centers for Medicare and Medicaid Services (CMS) issued Transmittal 2176 (Change Request 10955), which would establish a new series of Common Working File (CWF) edits intended to identify ambulance transports furnished in connection with outpatient hospital services that are properly bundled to the skilled nursing facility under the SNF Consolidated Billing regime. These new edits are set to go into effect on April 1, 2019. 

Why these edits are necessary?

In 2017, the HHS Office of the Inspector General conducted an investigation of ground ambulance claims that were furnished to Medicare beneficiaries during the first 100 days of a skilled nursing home (SNF) stay. Under the SNF Consolidated Billing regime, SNFs are paid a per diem, case-mix-adjusted amount that is intended to cover all costs incurred on behalf of their residents.  Federal regulations further provide that, with limited exceptions, the SNF’s per diem payment includes medically necessary ambulance transportation provided during the beneficiary’s Part A stay. The OIG’s report was issued in February 2019.

The OIG conducted a review of all SNF beneficiary days from July 1, 2014 through June 30, 2016 to determine whether the beneficiary day contained a ground ambulance claim line. The OIG excluded beneficiary days where the only ambulance claim line related to: (1) certain emergency or intensive outpatient hospital services or (2) dialysis services, as such ambulance transportation would be excluded from SNF Consolidated Billing. The OIG determined that there were 58,006 qualifying beneficiary days during this period, corresponding to $25.3 million in Medicare payments to ambulance suppliers.

The OIG then selected a random sample of 100 beneficiary days for review. The OIG determined that 78 of these 100 beneficiary days contained an overpayment for the associated ambulance claims, as the services the beneficiary received did not suspend or end their SNF resident status, nor was the transport for dialysis. The OIG determined that ambulance providers were overpaid a total of $41,456 for these ambulance transports. The OIG further determined that beneficiaries (or their secondary insurances) incurred an additional $10,723 in incorrect coinsurance and deductibles.

Based on the results of its review, the OIG estimates that Medicare made a total of $19.9 million in Part B overpayments to ambulance suppliers for transports that should have been bundled to the SNFs under SNF Consolidated Billing regime. The OIG estimated that beneficiaries (and their secondary insurances) incurred an additional $5.2 million in coinsurance and deductibles related to these incorrect payments.

The OIG concluded that the existing edits were inadequate to identify ambulance claims for services associated with hospital outpatient services that did not suspend or end the beneficiary’s SNF resident status, and which were not related to dialysis. The OIG recommended that CMS implement additional edits to identify such ambulance claims.

Overview of new claims processing edits

In response to the OIG’s report, CMS issued Transmittal 2176, which implements a new series of claims processing edits to identify ambulance claims associated with outpatient hospital services that should be bundled to the SNF. As noted above, these edits will go into effect on April 1, 2019.

These new claims processing edits are somewhat complicated. In order to properly understand how these claims edits will work, it is helpful to understand that CMS already has claims processing edits in place to identify hospital outpatient claims that should be bundled to the SNF. These CWF edits operate by referencing a list of Healthcare Common Procedure Coding System (HCPCS) or Current Procedural Terminology (CPT) codes that correspond to outpatient hospital services that are expressly excluded from SNF Consolidated Billing. Hospital claims for outpatient services that are submitted with one of these excluded codes bypass the existing CWF edits, and are then sent to the appropriate Medicare Administrative Contractor for further editing and payment. Hospital claims submitted without one of these codes are denied for SNF Consolidated Billing. For convenience, the list of HCPCS and CPT codes excluded from SNF Consolidated Billing is hereinafter referred to as the “Exempted Codes.”

The new edits for ambulance claims will compare Part B ambulance claims to the associated outpatient hospital claim to see whether or not that hospital claim is excluded from SNF Consolidated Billing.

Specifics related to new claims processing edits

Under these new edits, the CWF will reject an incoming ambulance claim whenever the beneficiary is determined to be in an SNF Part A stay if either:

  1. There is no associated outpatient hospital claims for the same date of service on file; or
  2. There is an associated outpatient hospital claim for the same date of service on file (paid or denied), but where that outpatient hospital claim does not contain at least one Exempted Code.

When an incoming ambulance claim is rejected by the CWF, it will be sent to the applicable Medicare Administrative Contractor and rejected (Part A Ambulance Providers) or denied (Part B Ambulance Suppliers) using the applicable Claim Adjustment Reason Code/Remittance Advice Remark Code for SNF Consolidated Billing.  In other words, the ambulance claim will be denied with an indication that youshould bill the SNF.

The Transmittal contains further instructions that the CWF be updated to identify previously rejected ambulance claims upon receipt of an associated hospital claim for the same date of service that contains an Exempted Code. Once identified, the Shared System Maintainer (SSM) is supposed to adjust the previously rejected or denied ambulance claim. At this point, the nature of that “adjustment” is unclear, i.e., it is unknown whether the SSM will automatically reprocess the ambulance claim for payment. The AAA is seeking additional clarification from CMS on this important point.

Potential concerns for ambulance providers and suppliers

Based on the current experience of hospital providers, the AAA is cautiously optimistic that the new edits can be implemented in a way that proper identifies ambulance transports associated with hospital outpatient claims that should be bundled to the SNF vs. those that correctly remain separately payable by Medicare Part B.

However, the AAA has some concerns with the manner in which CMS intends to apply these edits.  Ambulance providers and suppliers are typically in a position to submit their claims earlier than the corresponding hospital, many of which submit claims on a biweekly or monthly cycle.  This creates a potential timing issue. This timing issue arises because the edits will reject any ambulance claim that is submitted without an associated hospital claim on file.  In other words, even if the hospital outpatient service is properly excluded from SNF Consolidated Billing, the ambulance claim will still be rejected if it beats the hospital claim into the system. The hope is that CMS will subsequently reprocess the ambulance claim once the hospital claim hits the system. However, at this point in time, it is unclear whether these claims will be automatically reprocessed, or whether ambulance providers and suppliers will be forced to appeal these claims for payment.

One option available to ambulance providers and suppliers would be to hold these claims for a period of time, in order to allow the hospitals to submit their claims. By waiting for the hospital to submit its claim, you can ensure that your claims will not be denied solely due to the timing issue. This should eliminate the disruption associated with separately payable claims being rejected and then subsequently reprocessed and/or appealed. It would also give you a degree of certainty when billing the SNF for claims that are denied for SNF Consolidated Billing. However, holding claims carries an obvious downside, i.e., it will disrupt your normal cash flow.

To summarize, the implementation of these new edits will force ambulance providers and suppliers to rethink their current claims submission processes for SNF residents. Ambulance providers and suppliers will need to make a decision on whether to hold claims to minimize the potential for problems, or to continue their existing submission practices and deal with any issues as they arise.

AAA webinar on new SNF Consolidated Billing edits

March 27, 2019 | 2:00 PM Eastern
Speakers: Brian Werfel, Esq.
$99 for Members | $198 for Non-Members

Join AAA Medicare Consultant Brian Werfel, Esq., to go over the new SNF Consolidated Billing edits that go into effect April 1, 2019. These edits are being implemented by CMS in response to 2017 investigation by the HHS Office of the Inspector General that determined that CMS lacked the appropriate claims processing edits to properly identify ambulance transports provided in connection with hospital outpatient services that are not expressly excluded from SNF PPS. The implementation of these new edits will force ambulance providers and suppliers to rethink their current claims submission processes for SNF residents. Ambulance providers and suppliers will need to make a decision on what to do with these claims moving forward. Sign up today to make sure your service is ready!

Register for the Webinar

2017 National and State-Specific Medicare Data

The American Ambulance Association is pleased to announce the publication of its 2017 Medicare Payment Data Report. This report is based on the Physician/Supplier Procedure Summary Master File. This report contains information on all Part B and DME claims processed through the Medicare Common Working File and stored in the National Claims History Repository.

The report contains an overview of total Medicare spending nationwide in CY 2017, and then a separate breakdown of Medicare spending in each of the 50 states, the District of Columbia, and the various other U.S. Territories.

For each jurisdiction, the report contains two charts: the first reflects data for all ambulance services, while the second is limited solely to dialysis transports. Each chart lists total spending by procedure code (i.e., base rates and mileage). For comparison purposes, information is also provided on Medicare spending in CY 2016.

2017 National & State-Specific Medicare Data

Questions? Contact Brian Werfel at bwerfel@aol.com.

 

Congress Passes Ambulance Medicare Add-Ons

 

It is my pleasure to share with you that—just minutes ago—Congress passed the 5 year extension of the Medicare ambulance add-ons. The extension was part of the two-year budget deal reached by congressional leaders and passed by the Senate early this morning and then shortly thereafter by the House. The ambulance provisions in the final deal differ from the provisions passed earlier this week by the House in one key area – the collection of ambulance cost data. This means that we are truly in the endzone of the add-on payment extension process.

While we ask your continued patience as we jump through one last procedural hoop, I am confident that the add-ons will be back in effect as soon as the President signs the legislation. In today’s deeply divided political climate, I am proud of what we have accomplished through collaboration as an association and industry.

Here are the specifics of the final package:

  • 5 year extension of the ambulance Medicare add-ons through December 31, 2022, retroactive to January 1, 2018.
  • AAA’s preferred method of Cost data collection that provides flexibility to the Secretary of HHS in developing the system. Consultation with the industry is required so that it strikes the appropriate balance between obtaining meaningful data while not overly burdening or onerously penalizing the ambulance services.
  • The penalty for failing to report required data would be a reduction in payment up to 10% for the year following the year in which the data should have been submitted. AAA objected to the house proposed penalty of up to a year of Medicare payments clawback or withholding of payments. A clause is included to wave the penalty in cases of hardship.
  • A “pay-for” for the 5-year extension of the add-ons with a 13% cut to non-emergent dialysis transports – the AAA had objected to the offset and pushed for a cut targeted to just those entities which abuse the dialysis transport benefit. We were successful in reducing the initial cut from 22% to 13%. The AAA is actively working on other pay-for options that would replace the 13% cut with something targeting dialysis fraud and abuse.

Next Steps

All that remains to bring the add-ons into effect retroactively to January 1, 2018 are a few administrative formalities and the signature of the President, who has indicated his support of the agreement. Given the government shutdown, we are cautiously optimistic that this will proceed quickly. However, bumps are always a possibility—we will keep you informed! (Follow AAA on Twitter at @amerambassoc or Facebook for instant updates.)

Thank You

This week’s tremendous progress would not have been possible without months of effort by AAA volunteer leaders, advocacy experts, and staff, as well as support from our key champions in Congress.

I’d like to personally thank the AAA Government Affairs Committee, including Chair Jamie Pafford-Gresham and Vice Chair Shawn Baird, as well as the entire AAA Board for their hundreds of hours of hard work on this issue. We are all truly grateful for your dedication to moving mountains to find sustainable funding for EMS.

Last but certainly not least, thank you to the dozens of state ambulance associations and thousands of individual members who wrote letters to their Members of Congress in support of the add-ons. We truly couldn’t have made it this far without your support.

Again, thank you, and please stay tuned for final updates!

Mark Postma
President
American Ambulance Association
“Representing EMS in America”

House Passes Ambulance Medicare Add-Ons

Moments ago, the U.S. House of Representatives passed legislation which includes a five-year extension of the Medicare ambulance add-ons. The House voted 245 to 182 to pass a Continuing Resolution (CR) to fund the federal government beyond the current expiration date of February 8. The CR included a package of Medicare provider extenders including an extension of the temporary Medicare ambulance add-ons.

The ambulance provisions in the CR include the following:

  • A five-year extension of the temporary Medicare ambulance increases of 2% urban and 3% rural to base and mileage rates and 22.6% to the base rate in super rural areas. The extension would be retroactive to January 1, 2018 and expire on December 31, 2022.
  • The requirement for ambulance service suppliers to submit cost reports. The language is based on H.R. 3729 as reported by the House Ways and Means Committee but with new language providing the CMS Administrator with the discretion to apply a payment suspension or overpayment as the penalty for suppliers that do not submit timely, accurate and complete data after the initial two years.
  • To offset the cost of the add-ons extension, a further reduction of 13% in Medicare reimbursement for BLS non-emergency transports to and from dialysis centers. The initial reduction was 22% but the AAA was able to help lower the estimated cost of the add-ons and thus lower the percentage of the offsetting cut.

The CR now goes to the Senate for its consideration. The Senate is likely to act tomorrow, February 7.

We will keep you posted of new developments. Thank you for your continued support of the American Ambulance Association.

Mark Postma
President
American Ambulance Association
“Representing EMS in America”

Build Your Future with a Career in EMS

The U.S. Bureau of Labor Statistics expects career opportunities for EMTs and Paramedics to grow another 15 percent by 2026, far outpacing most other professions… With EMS agencies hungry for skilled providers, there has never been a better time to chart your career path in mobile healthcare.

This week, an editorial from AAA President Mark Postma was featured in a special Media Planet section on healthcare careers. Read the full article►

Medicare Extender Update

As president of your association, keeping you informed of our advocacy efforts is one of my top priorities. In keeping with this approach, I would like to share with you an update on the American Ambulance Association’s latest efforts on Capitol Hill. The temporary Medicare ambulance increases are currently scheduled to expire on December 31, 2017. And once again, Congress is waiting until the last minute to extend them. Thankfully, a long-term solution is on the horizon.

The House and Senate are in the process of negotiating the details of a Medicare provider extender package including our ambulance provisions. The House and Senate positions both include a five-year extension of the 2% urban, 3% rural, and super rural increases. Where their positions differ reflects the respective preferences of the Senate Finance and House Ways and Means Committees on how best to collect cost data from ambulance services suppliers and providers.

The Senate position is based on a Senate Finance Committee Discussion Draft from October 26 which includes the five-year extension of the increases as well as a data collection system based on the one from the Medicare Ambulance Access, Fraud Prevention and Reform Act (S. 967). The provision would direct CMS to collect data from a statistically significant number of ambulance service suppliers and providers. This would occur each year for the first three years, then a minimum of every three years thereafter. The penalty for not reporting data if selected would be a 10% cut in Medicare reimbursement for the following year. The language gives CMS flexibility in designing the system, and would place minimal burden on small ambulance service suppliers. The outcome would be usable data to further substantiate the need for rate increases and reform of the Medicare ambulance fee schedule.

The House position is based on H.R. 3729, which also includes the five-year extension of the increases. However, it adds mandatory annual cost reporting for ambulance service suppliers and providers as well. The AAA worked with the bill sponsors and Committee staff to modify the cost reporting language to reflect the unique nature of our industry. However, since ambulance service suppliers and providers aren’t paid based on cost reports, and cost reporting requirements are very stringent, there are several compatibility issues when attempting to apply this model to our industry. The primary problem is the penalty for not reporting timely data, as well as a new standard requiring the data to be accurate and complete. As a result, after the first two years of reporting, the penalty of an overpayment for not reporting timely, accurate, and complete data could be an entire year of Medicare payments. The AAA therefore prefers the Senate language due to its flexibility for our industry as well as its less severe penalty.

The good news is that the House and Senate are in agreement on a five-year extension of the increases. As part of the increase package, our industry will also have a data collection system to demonstrate that we are reimbursed below cost, and to make data-driven decisions on reforming the Medicare ambulance fee schedule. However, it is critical that we get the data collection provision right so that it provides useful information and is not overly burdensome for our members.

Thanks to our champions on Capitol Hill, member advocates, and our lobbying team, the super rural bonus payment has been in effect since 2003, and the urban and rural increases since 2008. Subsequently, we have successfully advocated for Congress to extend the increases eight times, including the current 33-month extension. However, with Congress pressed to address a number of priorities by the end of this year, a Medicare extenders package may not occur until early January.

Securing a five-year extension will require the action of our entire membership. I urge you to please write your members of Congress today in support of the Medicare ambulance increases!

Contact your members of Congress now>

2017 AAA Election Calendar

2017 Election Timeline

  • 8/31Nominations Close
  • 9/14 | Approval of Candidates by AAA Board of Directors
  • 10/11 | Voting Opens
    Election will be paperless and held online. Ballots will be delivered to AAA Active Member primary contacts via email.
  • 11/2 | Voting Closes 11:59pm
  • 11/14 | Election results announced at the 2017 AAA Annual Conference & Tradeshow.

Meet the Candidates

The AAA’s 2017 Election will be for the following positions:
  • Region I Director (CT, MA, ME, NH, NJ, NY, RI & VT)
  • Region II Director (AL, DE, DC, FL, GA, MD, MS, NC, PA, SC, VA, WV)
  • Region III Director (IL, IN, KY, MI, OH, TN WI)
  • Region IV Director (AR, IA, KS, LA, MN, MO, OK, ND, NE, SD, TX)
  • Region V Director (AK, AZ, CA, CO, HI, ID, MT, NM, NV, OR, UT, WA, WY)
  • Ethics Committee

 

 

Questions? Please contact acamas@ambulance.org for assistance.

Board of Director Nominations – Now Open!

Call For Nominations Now Open!

Submit a Nomination

Submit Candidate Questionnaire

In accordance with the Bylaws of the American Ambulance Association, it is time to call for members in good standing that wish to serve on the Board of Directors. The AAA is now seeking candidates for the following positions:
  • Region I Director (CT, MA, ME, NH, NJ, NY, RI & VT)
  • Region II Director (AL, DE, DC, FL, GA, MD, MS, NC, PA, SC, VA, WV)
  • Region III Director (IL, IN, KY, MI, OH, TN WI)
  • Region IV Director (AR, IA, KS, LA, MN, MO, OK, ND, NE, SD, TX)
  • Region V Director (AK, AZ, CA, CO, HI, ID, MT, NM, NV, OR, UT, WA, WY

Individuals who wish to be considered for an elected position as Regional Director must:

1. Be the designated representative of an Active member of the AAA, in good standing;

2. Be ready to devote time and effort to matters which concern the Board of Directors and to actively participate in all Board activities;

3. Be prepared to assist other AAA members with concerns and problems which relate to the ambulance industry and the workings of the AAA; and,

4. Understand that these positions provide no compensation for time or reimbursement for expenses. All travel-related expenses, including transportation, lodging and food are the responsibility of the individual and/or the sponsoring organization.

5. Be willing to comply with all governance policies of the association including, Conflict of Interest, Standards of Conduct, and Board Confidentiality, Public Comment and Lobbying Agreement (PDF).

6. Have served on at least one (1) Association committee within the past five (5) years prior to his or her declaration as a candidate for election as a Director.

There are no restrictions against an individual running for more than one position in the same election cycle, though no person shall hold more than one position simultaneously.

All those who wish to stand for election and believe they are qualified are requested to complete a Nomination Form as well as answer the Candidate Questionnaire which describes both their qualifications and reasons for wanting to participate in the leadership of the AAA.

(Please note that the may Nomination Form be completed by any designated contact for an AAA active member for him or herself, or on behalf of another designated contact at a fellow AAA active member service. The Candidate Questionnaire must be completed by the nominee.)

Candidates’ statements and pictures, as well as the position(s) for which they are running for will be listed on the AAA website.

2017 Election Timeline

  • 8/31Nominations Close
  • 9/14 | Approval of Candidates by AAA Board of Directors
  • 10/3 | Voting Opens
    Election will be paperless and held online. Ballots will be delivered to AAA Active Member primary contacts via email.
  • 11/2 | Voting Closes 11:59pm
  • 11/14 | Election results announced at the 2017 AAA Annual Conference & Tradeshow.

Both forms must be submitted to by Thursday, August 31, 2017

Step 1: Nomination Form    Step 2: Candidate Questionnaire

Questions? Please contact acamas@ambulance.org for assistance.

House Introduces H.R. 3236 – Write to Your Reps!

Take Action for Extending Medicare Ambulance Relief

Ask your Representatives to Support H.R. 3236 – The Ambulance Medicare Budget and Operations Act of 2017

The current 33-month extension of the Medicare add-on payments is set to expire at the end of December 2017. Losing these add-on payments would be a devastating blow to ambulance services across the country. It is crucial that the payments be extended as we push for a long-term solution. H.R. 3236 introduced by Reps. Nunes, Upton, and Welch would extend the current temporary Medicare add-ons for five years. More details about the Bill can be found below. Let your Representative know that you support H.R. 3236 — Here are three quick and easy ways to get involved!

Writing to your members of Congress only takes 2 clicks, follow these simple steps:

1. Enter contact information below (required by Congressional offices) and click “Submit”
2. On the next page you’ll see the letter to your Representative (Message 1) and the letter(s) to your Senators  (Message 2) – click “Submit Messages”
Feel free to personalize your letter(s) before submitting them.

Active on Social Media? Tweet at your Representative asking for their support of H.R. 3236!

  • Authorize Your Account
  • Enter Contact Information
  • Tweet! (Tweet will be auto-generated with your Senators tagged)
Know your Senators’ Twitter accounts already? Tweet:
“#ambulance svs in your district need you, @[your Representative]! Please co-sponsor HR 3236  to help us continue to provide quality #EMS!”

Post on Facebook why H.R. 3236  is important! Be sure to tag your Representative and encourage others to share your post! Ask others to write letters of support as well! http://bit.ly/AAAbill

More About Our Bill H.R. 3236, the Ambulance Medicare Budget and Operations Act of 2017:
Legislation to extend the Medicare ambulance add-on payments for five years has been introduced by Representatives Nunes, Upton, and Welch (H.R. 3236).
Specifically, the bill:

  • Provides Medicare Ambulance Relief, by extending for five years the current temporary 2 percent urban, 3 percent rural, and super rural bonus payments.
  • Requires the Medicare Payment Advisory Commission (MedPAC) to submit a report to Congress detailing the burden of cost reports on the ambulance industry and accuracy of the data received through ambulance cost reports and making recommendations on whether the system should be modified no later than July 1, 2019.
  • Requires CMS to work with stakeholders in the development of an ambulance cost report.

Discovering the Meaning of EMS Week

Being in EMS since 1990 I can certainly tell you I have seen numerous EMS Week celebrations come and go. Did you know EMS week owes its founding to the American College of Emergency Physicians? In 1974, ACEP asked former President Gerald R. Ford to declare November 3-10 as National Emergency Medical Services Week. Since then, ACEP has moved the annual observance numerous times, finally landing on the third week in May. This move provided a distinction between EMS and Fire Prevention week.

EMS has always been a part of my life, from the EMT-M class I took in January 1990 to becoming an RN in 2008.  I have done almost everything in EMS a person could do, volunteer EMT, Paramedic, Critical Care Education, ED RN and now vice president of EMS Education at OnCourse Learning.

Let’s discuss ideally what EMS providers actually want most for EMS Week. This year, let’s dismiss all of the usual tchotchkes, mugs, t-shirts, hot dogs, pens and flash lights. I can honestly say after 25+ years, I’ve gotten it all and am a bit tired of it. The ED sponsored pizza, while a very kind gesture, always seems to go uneaten for a variety of reasons.

Let’s face it, we know we are under paid and over worked. Although I am always grateful for the sentiment people have for us as a profession during EMS week I’d prefer recognition more frequently, even every day. Don’t get me wrong, I’m not being ungrateful, the hot dogs and pens are appreciated. But let’s focus on what matters most for pre-hospital professionals – better pay, working conditions, and meaningful education.

Which brings me to the area I can influence most. Not the everyday education, you know card certs PHTLS, ITLS, APLS, PEPP, and EVDT etc. I want something more. I want continuing education that excites me. That embraces my desire to improve EMS and helps us all to change and improve the care we deliver to our patients. To change the protocols that guide us in the care we provide. Basically, what I am asking for is a seat at the table, minus the pens and hots dogs. Let’s start with a better educational foundation, a voice in the care we provide and deliver better care to those who rely on us to care for their loved ones.

About the Author
Scott F. McConnell is Vice President of EMS Education for OnCourse Learning and one of the Founders of Distance CME.  Since its inception in 2010, more than 10,000 learners worldwide have relied on Distance CME to recertify their credentials. Scott is a true believer in sharing not only his perspectives and experiences but also those of other providers in educational settings.

Write to Your Senators! Support S.967

Take Action for Permanent Medicare Ambulance Relief

Ask your Senators to Support S.967 – 2017 Medicare Ambulance Access, Fraud Prevention, and Reform Act

The current 33-month extension of the Medicare add-on payments is set to expire at the end of December 2017. Losing these add-on payments would be a devastating blow to ambulance services across the country. It is crucial that the payments be made permanent as we push for a long-term solution. More details about the Bill can be found below. Let your Senators know that you support S. 967 — Here are three quick and easy ways to get involved!

Writing to your members of Congress only takes 2 clicks, follow these simple steps:

1. Enter contact information below (required by Congressional offices) and click “Submit”
2. On the next page you’ll see the letter(s) to your Senators – click “Submit Messages”

Active on Social Media? Tweet at your Senators asking for their support of S. 967!

  • Authorize Your Account
  • Enter Contact Information
  • Tweet! (Tweet will be auto-generated with your Senators tagged)
Know your Senators’ Twitter accounts already? Tweet:
“#ambulance svs in your state need you, @[your Senators]! Please co-sponsor S. 967 to help us continue to provide quality #EMS!”


Post on Facebook why S. 967 is important! Be sure to tag your Senators and encourage others to share your post! Ask others to write letters of support as well! http://bit.ly/AAAbill

More About Our Bill S. 967, the 2017 Medicare Ambulance Access, Fraud Prevention, and Reform Act:
Permanent ambulance relief legislation has been introduced by Senators Stabenow, Roberts, Schumer, Collins, and Leahy (S. 967). This legislation will allow ambulance service providers to maintain high quality ambulance services and budget for the future.
Specifically, the bill:

  • Provides Medicare Ambulance Relief, by permanently incorporating the current temporary 2 percent urban, 3 percent rural, and super rural bonus payments into the Medicare ambulance fee schedule rates.
  • Requires the Centers for Medicare and Medicaid Services (CMS) to submit a report to Congress detailing the features of a reformed payment system for ambulance services under the Medicare program no later than July 1, 2019.
  • Modifies the process for the transport of dialysis patients by requiring the Department of Health and Human Services to establish a process for the prior authorization of coverage for such patients.
  • Treat ambulance services designated as “suppliers” as “providers” for certain purposes under Medicare.
  • Specifies CMS to work with stakeholders in the development of a data collection system for ambulance entities that defines the various types of ambulance entities as well as the relevant cost and data elements required for submission.

Support AAA’s Medicare Relief Legislation, S. 967

Dear Fellow Members,

As you know, the Medicare ambulance add-on payments are set to expire on December 31, 2017. I’m proud to share with you that today, due to AAA advocacy efforts, permanent ambulance relief legislation was introduced by Senators Stabenow, Roberts, Schumer, Collins, and Leahy.

This bill, S.967, “Medicare Ambulance Access, Fraud Prevention, and Reform Act” would make permanent the vital urban and rural Medicare add-ons and super-rural bonus payments. Although some changes are likely during the committee markup process, we are cautiously optimistic that it will also carry through proposals to reclassify ambulance organizations as providers of health care (not suppliers of transportation), as well as a cost data collection system that does not place undue burden on ambulance services.

On behalf of the AAA, I’d like to extend my deepest thanks to Senators Stabenow, Roberts, Schumer, Collins, and Leahy for sponsoring the legislation, as well as the AAA Board, Government Affairs Committee, advocacy consultants, and staff who worked so diligently to build support on Capitol Hill.

Over the coming months, AAA will continue to connect with policymakers to build support for sustainable ambulance Medicare reimbursement. However, we need your help to ensure that this critical revenue remains in place. We ask that you please contact your Senators to voice your support for S. 967. AAA makes it easy to connect with your legislators through our online advocacy tool—please use it today to quickly send messages expressing the importance of the legislation to your ambulance service and the communities you serve.

If possible, we ask that you also work with fellow ambulance providers in your area to schedule in-person meetings with your legislators’ offices. If you arrange a meeting in your home state, please contact AAA staff at info@ambulance.org for talking points to support your conversation.

Now, more than ever, we need the active participation of each member organization to ensure our collective future! Thank you in advance for your assistance with advocacy outreach, as well as for your continued membership to the American Ambulance Association.

Mark Postma
President, American Ambulance Association
“Representing EMS in America”

CMS Announces 2017 Inflation Factor

The Centers for Medicare and Medicare Services (CMS) issued Transmittal 3625 officially announcing that the inflation factor for payments under the Medicare ambulance fee schedule for 2017 will be 0.7%.

The calculation for determining the Medicare ambulance inflation factor is as follows: Consumer Price Index – Urban (which is the change in the CPI-U from June to June) minus the non-farm business multi-factor productivity adjustment (MFP) as projected by the Secretary of HHS (10-year average). The CPI-Urban for 2017 is 1.0% with a MFP of 0.3% which equals the 0.7% inflation factor. As part of the Affordable Care Act, a productivity adjustment is subtracted from the CPI-Urban for the final inflation update.

A Preliminary Estimate of 2017 Medicare Rates

 On July 15, 2016, the Bureau of Labor Statistics released its monthly report on inflation.  This release includes the change in the Consumer Price Index for all urban consumers (CPI-U) for June 2016.  As a result, it is now possible to make a preliminary estimate of the Ambulance Inflation Factor (AIF) for calendar year 2017.  The AIF is main factor that determines the increase (or decrease) in Medicare’s payment for ambulance services.

Calculating the 2017 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.  For 2017, this means the 12-month period ending on June 30, 2016.  Starting in calendar year 2011, the change in the CPI-U is 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 resulting AIF is then applied to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.

The formula used to calculate the change in the CPI-U is limited to positive increases.  Therefore, even if the change in the CPI-U was negative over a 12-month period (a rarity in the post-war era), the change in the CPI-U cannot be negative.  However, when the MFP reduction is applied, the statute does permit a negative AIF for any calendar year.  That is precisely what occurred in 2016, where the change in the CPI-U was 0.1% and the MFP was 0.5%.  As a result, the industry saw an overall reduction in its Medicare rates of 0.4%.

Fortunately, it seems unlikely that we will see a negative AIF in 2017.  For the 12-month period ending in June 2016, the Bureau of Labor Statistics (BLS) currently calculates the change in the CPI-U to be exactly 1.00%.

CMS has yet to release its estimate for the MFP in calendar year 2017.  However, assuming CMS’ projections for the MFP are similar to last year’s projections, the 2017 MFP is likely to be in the 0.5% range.

Therefore, at this time, my best guess is that the 2017 Ambulance Inflation Factor will be a positive 0.5%.

Please note that this estimate assumes the Bureau of Labor Statistics does not subsequently revise its inflation estimates.  Please note further that this projection is based on the MFP being similar to last year.  To the extent either of these numbers changes in the coming months (up or down), my estimate of the 2017 AIF would need to be adjusted accordingly.  Ultimately, the 2017 AIF will be finalized by CMS by Transmittal, which typically occurs in the early part of the 4th quarter.

Impact on the Medicare Ambulance Fee Schedule

 Assuming all other factors remained the same, calculating your 2017 Medicare rates would be a relatively simple exercise, i.e., you would simply add 0.5% to your 2016 rates.  However, as part of its 2017 Physician Fee Schedule Proposed Rule (issued on July 15, 2016), CMS proposed extensive changes to the GPCIs.   These changes can be viewed by going to the Physician Fee Schedule page on the CMS website and clicking the link for the “CY 2017 PFS Proposed Rule GPCI Public Use Files” (located in the Downloads section).  You would then need to open the file for “CY 2017 Proposed Addendum E.”

If the PE GPCI in your area is proposed to increase, you can expect your 2017 Medicare rates to increase by slightly more than 0.5%.  If the PE GPCI in your area is proposed to decrease, you can expect your 2017 Medicare rates to increase by slightly less than 0.5%.

If you are looking for a more precise calculation of your rates, you will need to use the following formulas:

Ground Ambulance Services

Medicare Allowable = (UBR x .7 x GPCI) + (UBR x .3)

Air Ambulance Services

Medicare Allowable = (UBR x .5 x GPCI) + (UBR x .5)

 In this formula, the “UBR” stands for the unadjusted base rate for each HCPCS code.   These are calculated by multiplying the national conversation factor by the relative value unit assigned to each base rate.  To save some time, estimates for the 2017 unadjusted base rates are reproduced below:

Base Rate (HCPCS Code)

2017 Unadjusted Base Rate
BLS non-Emergency (A0428)                     $221.84
BLS emergency (A0429)                     $354.95
ALS non-emergency (A0426)                     $266.21
ALS emergency (A0427)                     $421.51
ALS-2 (A0433)                     $610.08
Specialty Care Transport (A0434)                     $721.00
Paramedic Intercept (A0432)                     $388.23
Fixed Wing (A0430)                     $3,010.52
Rotary Wing (A0431)                     $3,500.17

 

Plugging these UBRs into the above formulas will result in adjusted base rates for each level of ground and air ambulance service.  The final step would be to apply the current adjustments for urban (2%), rural (3%) and super-rural (22.6% over the corresponding rural rate).

2017 Projected Rates for Mileage:

At this time, I am estimating the following rates for Medicare mileage:

Base Rate (HCPCS Code) 2017 Unadjusted Base Rate
Ground Mileage – Urban                     $7.28
Ground Mileage – Rural Miles 1 – 17                     $11.02
Ground Mileage – Rural Miles 18+                     $7.35
Fixed Wing Mileage – Urban                     $8.54
Fixed Wing Mileage – Rural                     $12.81
Rotary Wing Mileage – Urban                     $22.79
Rotary Wing Mileage – Rural

 

                    $34.19

Please keep in mind that a number of assumptions went into these projections.  The Bureau of Labor Statistics can revise its inflation figures in the coming months.  CMS may announce an MFP projection that differs from what we expect.  CMS may also announce that it is electing not to finalize its proposed changes to the GPCI (highly unlikely).   If any of these assumptions was to change, these projections would need to be revised.  Therefore, I would suggest that you view these as rough estimates at best.  The AAA will update members as more information becomes available in the coming months. 

Have an issue you would like to see discussed in a future Talking Medicare blog?  Please write to me at bwerfel@aol.com.

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