Tag: 2019

COVID-19 Coronavirus EMS Advisory 1

This guidance is written to offer American Ambulance Association members the situational background and a list of resources and websites with which to draw guidance and further updates on the latest situation with COVID-19, colloquially referred to as “Coronavirus.” Key information for this update has been drawn from the NHTSA EMS Focus series webinar What EMS, 911 and Other Public Safety Personnel Need to Know About COVID-19, which took place on February 24, 2020. The on-demand recording is available below.

General Information

Background

The COVID-19 Coronavirus Disease was first reported in Wuhan China in December 2019. CDC identifies that it was caused by the virus SARS – CoV-2. Early on, many patients were reported to have a link to a large seafood and live animal market. Later, patients did not have exposure to animal markets which indicates person-to-person transmission. Travel-related exportation of cases into the US was first reported January 21, 2020. For reference the first North American EMS experience of  COVID-19 patient transport, including key lessons learned, can be found in the EMS 1 article Transporting Patient 1.

Spread and Identification

Global investigations are now ongoing to better understand the spread. Based on what is known about other coronaviruses, it is presumed to spread primarily through person-to-person contact and may occur when respiratory droplets are produced when an infected person costs or sneezes. Spread could also occur when touching a surface or object that has the virus on it and when touching the mouth, nose, or eyes. Again, research is still ongoing, and advice and guidance will inevitably follow.

For the cases that have been identified so far, those patients with COVID19 have reportedly had mild to severe respiratory illness with symptoms including fever and shortness of breath. Symptoms have typically appeared 2 to 14 days after exposure. Both the WHO and CDC advise that patients that have been to China and develop the symptoms should call their doctors.

COVID-19 Prevention and Treatment

To date, 30 international locations, in addition to the US, have reported confirmed cases of   COVID-19 infection. Inside the US, two instances of person-to-person spread of the virus have been detected. In both cases, these occurred after close and prolonged contact with a traveler who had recently returned from Wuhan, China.

The CDC activated its Emergency Operations Center (EOC) on January 21 and is coordinating closely with state and local partners to assist with identifying cases early; conducting case investigations; and learning about the virology, transmission, and clinical spectrum for this disease. The CDC is continuing to develop and refine guidance for multiple audiences, including the first responder and public safety communities.

As at the date of publication there is still no specific antiviral treatment licensed for   COVID-19, although the WHO and its affiliates are working to develop this.

The following are recommended preventative measures for  COVID-19 and many other respiratory illnesses:

  • Wash your hands often with soap and water for at least 20 seconds.
  • Use an alcohol-based hand sanitizer with at least 60% if soap and water are not readily available.
  • Avoid touching your eyes, nose, and mouth with unwashed hands.
  • Avoid contact with people who are sick.
  • Stay home when you are sick.
  • Cover your cough or sneeze with a tissue, then throw it away.
  • Clean and disinfect frequently touched objects and surfaces.

Interim Guidance for EMS and 911

The Centers for Disease Control (CDC) has issued its Interim Guidance for Emergency Medical Services (EMS) Systems and 911 Public Safety Answering Points (PSAPs) for COVID-19 in the United States.

The guidance identifies EMS as vital in responding to and providing emergency treatment for the ill. The nature of our mobile healthcare service delivery presents unique challenges in the working environment. It also identifies that coordination between PSAPs and EMS is critical.

Key points are summarized below:

Recommendations for 911 PSAP Locations

The link between PSAPs and EMS is essential. With the advent of COVID19 there is a need to modify caller queries to question callers and determine the possibility that the call concerns a person who may have signs or symptoms and risk factors for COVID19.

The International Academy of Emergency Dispatch (IAED) recommends that agencies using its Medical Priority Dispatch System (MPDS) should use its Emerging Infectious Disease Surveillance (EIDS) Tool within the Sick Person and Breathing Problem protocols. For those that are not MPDS users, IAED is offering its EIDS surveillance Tool for Coronavirus, SRI, MERS and Ebola-free of charge under a limited use agreement.

Recommended Personal Protective Equipment (PPE)

The CDC recommends that while involved in the direct care of patients the following PPE should be worn:

  • Single pair of disposable examination gloves
  • Disposable isolation gown
  • Respiratory protection (N95 or higher)
  • Eye Protection (goggles or disposable face shield)

EMS Transport of a Patient Under Investigation (PUI) or Patient with Confirmed COVID19

  • Notify receiving healthcare facility so appropriate precautions can be put in place
  • Discourage family and contacts from riding in transport vehicle
  • Isolate the vehicle driver from the patient compartment by closing the windows between compartments and ensuring that the vehicle ventilation system is set to the non-recirculated mode
  • Document patient care

Cleaning EMS Transport Vehicles After Transporting PUI or Patient

  • Don PPE for cleaning with disposable gown and gloves, facemask, and goggles or face shield if splashes are anticipated
  • Routine cleaning and infection procedures should follow organizational standard operating procedures
  • Use protect use products with EPA-approved emergent viral pathogens claims

Once transport is complete, organizations should notify state or local public health authorities for follow up. Additionally agencies should (if not done already) develop policies for assessing exposure risk and management of EMS personnel, report any potential exposure to the chain of command, and watch for fever or respiratory symptoms amongst staff.

Employers Responsibilities

While not specific to COVID-19, agencies should:

  • Assess current practices and policies for infection control
  • Job- or task-specific education and training
  • PPE training and supply
  • Decontamination processes and supplies

Local EMS Considerations

  • PPE supplies
  • 911 and EMD call taking activities
  • Appropriate approach to potential patients
  • Educational resources for EMS personnel
  • Interaction with local public health/healthcare systems/emergency management
  • Interaction with local fire and law enforcement
  • Considerations for local jails

Further Reading

Conclusion

The COVID19 situation constantly evolving. Agencies should defer to their local EMS authorities, Public Health departments, and the CDC for definitive guidance. Going forward, the AAA will continue to both monitor the disease and alert issues to the membership.

2019 AAA Board of Directors Election Results

The winners of the 2019 AAA Board of Directors election are listed below. Please join us in thanking all candidates for their service to the American Ambulance Association.

Region I

Director (2021)

Jim Finger
Chief Executive Officer/ Administrator
Regional Ambulance Service
Rutland, VT


 

Alternate Director

Reginald Allen
Chief Executive Officer
CHS Mobile Integrated Health Care
Rochester, NY

 

Region II

Director (2021)

Josef Penner
Executive Director
Mecklenburg EMS Agency – Medic
Charlotte, NC

 


Alternate Director

Terence Ramotar
Regional Director
American Medical Response
Tampa, FL

 

Region III

Director (2021)

Wayne Jurecki
Vice President / Chief Operating Officer
Bell Ambulance Service, Inc.
Milwaukee, WI

 


 

Alternate Director

Tom Tornstrom
Executive Director
Gundersen Tri-State Ambulance
La Crosse, WI

 

Region IV

Director (2021)

Jamie Pafford-Gresham
Chief Executive Officer
Pafford Medical Services, Inc.
Hope, AR

 


 

Alternate Director

David Tetrault
Administrator/Chief Executive Officer
St. Francois County Ambulance District
Farmington, MO

 

Region V

Director (2021)

Chris Archuleta
Chief Executive Officer
Superior Ambulance Service, Inc.
Albuquerque, NM


Alternate Director

JD Fuiten
Owner & President
Metro West Ambulance Service, Inc.
Hillsboro, OR

 

CMS Announces 2020 Ambulance Inflation Factor

On October 4, 2019, CMS issued Transmittal 4407 (Change Request 11497), which announced the Medicare Ambulance Inflation Factor (AIF) for calendar year 2020.

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 2018, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased 1.6%. CMS further indicated that the CY 2020 MFP will be 0.7%. Accordingly, CMS indicated that the Ambulance Inflation Factor for calendar year 2019 will be 0.9%.

2019 AAA Award Winners Announced

The American Ambulance Association is proud to announce this year’s award winners. Awards will be presented at the AAA Annual Conference & Trade Show Membership Meeting on Tuesday, November 5, 2019. Please join us in congratulating this year’s winners!

J. Walter Schaefer Award

Dr. John Becknell

The J. Walter Schaefer Award is given annually to an individual whose work in EMS has contributed positively to the advancement of the industry as a whole. Dr. John Becknell has achieved this honor for his lifelong commitment to improving the health and wellness of mobile healthcare professionals.

Robert L. Forbuss Lifetime Achievement Award

Dr. John Russell

The Robert L. Forbuss Lifetime Achievement Award is named in honor of the first Executive Director of the American Ambulance Association. It recognizes a volunteer leader who has made a significant long-term impact on the association. your decades of service, commitment, and dedication to the private ambulance industry, the AAA, and its members. Dr. John Russell has achieved this through his many years of service to the AAA as a volunteer leader.

President’s Award

These awards are bestowed by the President to volunteer leaders who have shown commitment to the advancement of the AAA, above and beyond the call of duty.

Wayne Jurecki

The American Ambulance Association is proud to honor Wayne Jurecki with the 2019 President’s Award. Wayne is being honored for his servant leadership and consummate professionalism, and commitment to the AAA.

Gibson McCullagh

The American Ambulance Association is proud to honor Gibson McCullagh with the 2019 President’s Award. Gibson is being honored for his service as a rising mobile healthcare leader who will help shape the future of our industry.

2019 Affiliate of the Year

Stryker

The American Ambulance Association (AAA) is proud to award Stryker with the 2019 Affiliate of the Year Award. Stryker has achieved this honor through their ongoing support of AAA’s educational programs and events.

EMS Partnership of the Year

The Savvik Foundation

The EMS Partnership of the Year Award is given to an organization or individual whose collaboration with the AAA enhances educational programs, legislative priorities, and/or member benefits. The Savvik Foundation has achieved this honor by developing a grant program for small providers to receive cost collection education.

Distinguished Service Award

Aidan V. Camas

AAA Manager of Federal & State Government Affairs Aidan V. Camas is receiving a 2019 Distinguished Service Award in recognition of his dedication and commitment to the AAA’s advocacy efforts.

Join us once again in congratulating the 2019 winners! Learn more about the Annual Conference & Trade Show.

 

2019 AAA Election—Floor Nominations

To All AAA Members,

In accordance with the AAA Bylaws, floor nominations for the Board, Ethics and Honorary Membership positions for the 2019 election will be accepted by the AAA board prior to their approval of the slate of candidates. If you are interested in a position or nominating another member, but have not filled out your nomination form or candidate’s questionnaire, please contact a AAA Board member so they can place your name on the slate prior to the closing of nominations. All floor nominations must be received by 5:00pm Eastern on Wednesday, September 18, 2019. If you have any questions, please contact Maria Bianchi, AAA Executive Director (mbianchi@ambulance.org).

Please follow this link to contact a AAA board member.

Nominations Open – AAA Board of Directors!

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 employed by a AAA active member for him or herself, or on behalf of another designated contact employed 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 once their candidacy has been certified by the Nominating Committee.

2019 Election Timeline

  • 8/5 | Nominations Open
  • 9/9 | Nominations Close
  • Week of September 16th Approval of Candidates by AAA Board of Directors
  • 9/30 | Voting Opens
    Election will be paperless and held online. Ballots will be delivered to AAA Active Member primary contacts via email.
  • 10/25 | Voting Closes 11:59pm
  • 11/5 | Election results announced at the 2019 AAA Annual Conference & Tradeshow.

Both forms must be submitted to by Monday, September 9, 2019

Step 1: Nomination Form    Step 2: Candidate Questionnaire

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

2019 Ambulance Ride-Along Toolkit

AAA ambulance emt member legislation

2019 Ride-Along Toolkit Now Available!

Educating your members of Congress about ambulance industry issues makes them much more likely to support your efforts. An easy and effective way to educate them is to invite them to participate in a local Ambulance Ride-Along!

Congress is scheduled to adjourn on July 27 for their August congressional recess with members of Congress returning home to their districts and states. This is the perfect opportunity for you to educate your members of Congress about those issues, in particular the Public Safety Officers Benefit (PSOB), permanent ambulance relief and ambulance cost data collection which are important to your operation. The most effective way to deliver these key messages is to host your member of Congress or their staff on a tour of your operation and an ambulance ride-along. The AAA has made the process of arranging a ride-long or scheduling a meeting easy for you with our 2019 Congressional Ride-Along Toolkit.

Are you willing to host a Member of Congress at your service but unsure of how to set it up? Email or call Aidan Camas at acamas@ambulance.org – (202) 802-9026 and Aidan can help you set up a meeting.

Everything you need to arrange the ride-along or schedule a meeting is included in the Toolkit. Act now and invite your elected officials to join you on an Ambulance Ride-Along!

Member Update on Balance Billing

This morning Ruth Hazdovac and Aidan Camas of AAA staff and Kathy Lester, Esq, Healthcare Consultant to the AAA attended a briefing held by the House Energy & Commerce Committee on the issue of surprise/balance billing. At the briefing, staff for Chairman Frank Pallone (D-NJ) and Ranking Member Greg Walden (R-OR) announced that they would be releasing a bipartisan discussion draft, the No Surprises Act, which would “protect consumers from surprise medical bills and increase transparency in our health care system.”

As of now, ground and air ambulances are NOT included in the discussion draft. However, the committee is asking for comments on ground and air ambulance and recommendations on how to provide relief to the consumer in this area. The AAA has a Balance Billing Work Group that is hard at work developing a policy recommendation that will work for our members.

The House Ways and Means Health Subcommittee Chairman Lloyd Doggett also announced today that the Health Subcommittee will hold a hearing next week entitled “Hearing on Protecting Patients from Surprise Medical Bills.” AAA Staff will be at the briefing and provide a timely update to membership on any developments.

The AAA team will be submitting comments and policy recommendations based off the work of the Balance Billing Work Group to both the Energy & Commerce and Ways & Means Committee to ensure that the views of our members are well represented. We will also be reaching out to AAA members in the states of key policymakers on the Committees to submit comments, as well. The AAA will also provide members with key talking points in the event they are contact by their Members of Congress or their staff.

Questions? Contact Us

If you have questions about the discussion draft or balance billing initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

Ruth Hazdovac – AAA Senior Manager of Federal Government Affairs
rhazdovac@ambulance.org | (202) 802-9027

Aidan Camas – Manager of State & Federal Government Affairs
acamas@ambulance.org | (202) 802-9026

Thank you for your continued membership and support.

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

AAA Webinar Wednesday, March 6: Tools for Billing Services and Other Vendors

Whether you contract with a third-party billing service, or have an internal billing department, the upcoming Ambulance Cost Data Collection (ACE) webinar hosted by the AAA on Wednesday, March 6 is a can’t miss.

As we get closer to new Cost Data Collection requirements taking effect across the ambulance service community, the American Ambulance Association has been developing Ambulance Cost Education tools and information to make it easier for services of all sizes and types to report. Billing services and vendors are a key component of the Cost Data Collection process, and if you have not already involved your contracted servicers or employees, this is a great time to start.

Tools for Billing Services and Other Vendors, presented by Ambulance Cost Education faculty member Aaron Director, will discuss the web-based reporting tool being developed, and share some ideas for vendors to create an integrated, seamless tool through partnership with the AAA. This is the ideal webinar for vendors that serve the ambulance community, and we encourage you to reach out and share this information broadly.  Invite them to participate and get involved!

We know things go better when we work together, and that is why the AAA is working so hard to make sure the Cost Data Collection process is inclusive. These webinars are available as part of a subscription package or On Demand. To learn more about Ambulance Cost Data Collection and all the American Ambulance Association is doing to help services across the country prepare, visit www.ambulancereports.org.  You will find both free resources and paid subscriptions are available to fit your budget and help your service prepare for the future of EMS.

 

 

AAA Releases 2019 State Medicaid Ambulance Rate Survey

The AAA is pleased to release its 2019 State Medicaid Rate Survey. This survey sets forth the fee-for-service Medicaid rates for all 50 states. For each state, the Survey lists the rate paid for each of the following procedure codes:

  • A0428 – BLS Non-Emergency
  • A0429 – BLS Emergency
  • A0426 – ALS Non-Emergency
  • A0427 – ALS Emergency
  • A0433 – ALS-2
  • A0434 – SCT
  • A0225 – Neonate Transport
  • A0998 – Treatment, No Transport
  • A0425 – Mileage
  • A0422 – Oxygen
  • A0382/A0398 – BLS/ALS Routine Disposable Supplies
  • A0420 – Wait Time
  • A0424 – Extra Attendant

Download the Survey

Download the Survey as Spreadsheet

The rates set out in this survey are based on publicly available information provided by the various State Medicaid agencies. While the AAA has taken steps to verify the accuracy of the information on this Survey, it is possible that the rates provided in the Survey may not reflect changes to a state’s reimbursement policies that have not been made publicly available. These rates may not also not reflect any emergency budgetary measures or other temporary reductions imposed by a state.

The AAA’s goal is to make this Survey as accurate as possible. Therefore, if you believe the rates for your state are inaccurate, please contact the AAA at info@ambulance.org or me at bwerfel@aol.com.

CMS Declines to Extend Temporary Moratorium

On January 30, 2019, the Centers for Medicare & Medicaid Services (CMS) announced that it had elected not to extend its temporary moratoria on the enrollment of new Medicare Part B non-emergency ground ambulance providers and suppliers in the states of New Jersey and Pennsylvania. These enrollment moratoria expired on January 29, 2019.

AAA Releases 2019 Medicare Rate Calculator

AAA 2019 Medicare Rate Calculator Now Available!

The American Ambulance Association is pleased to announce the release of its 2019 Medicare Rate Calculator tool. The AAA believes this is a valuable tool that can assist members in budgeting for the coming year. This calculator has been updated to account for recent changes in Medicare policies, including the 2019 Ambulance Inflation Factor (2.3%) and continuation of the current temporary add-ons.

To access the Rate Calculator, please CLICK HERE.

Download the 2019 Rate Calculator

OSHA Reminder 2019

OSHA Injury Posting & Reporting of 2018 Injury Data

It is important that employers remember that they must post a copy of their OSHA Form 300A which is a summary of workplace injuries starting February 1, 2018 through April 30, 2018.  The OSHA Form 300A is a summary of all job-related injuries and illnesses that occurred in an employer’s workplace during 2018.  If a company recorded no injuries or illnesses in 2018, the employer must enter “zero” on the total line. The form must be signed and certified by a company executive. The OSHA Form 300A Injury Summary must be displayed in a common area where notices to employees are usually posted.  In addition to posting these reports in the workplace, covered employers should be electronically submitting their 2018 workplace injury data to OSHA via the Injury Tracking Application (ITA).  If members need assistance with the workplace posting or electronic injury reporting submission, contact the AAA.

2019 OSHA Penalty Adjustment

Also, a reminder to employers who are subject to OSHA or to those who operate in a state with an OSHA approved state level plan, the penalty amounts for OSHA violations are increasing effective the publication of the new rates in the Federal Register.  In accordance with the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the Department of Labor is required to adjust penalties for inflation each year. New penalties for willful and repeat violations are $132,598 per violation; serious, other-than-serious, and posting requirements are $13,260 per violation; and failure to correct violations is $13,260 for each day the condition continues.  The new penalty details can be found in the OSHA Enforcement Section of their website.

Federal District Court Judge Strikes Down the ACA

On December 14, 2018, a federal district court judge for the Northern District of Texas issued a ruling striking down the Affordable Care Act (ACA) on the grounds that the Individual Mandate was unconstitutional, and that the rest of the law cannot withstand constitutional scrutiny without the Individual Mandate.

District Court Judge Reed O’Connor’s decision relates to a lawsuit filed earlier this year by 20 states and two individuals. The plaintiffs argued that the Tax Cuts and Jobs Act of 2017 — which amended the Individual Mandate to eliminate the penalty on individuals that failed to purchase qualifying insurance effect January 1, 2019 — rendered the Individual Mandate unconstitutional. The plaintiffs further argued that the Individual Mandate was inseverable from the rest of the ACA, and, therefore, that the entire ACA should be struck down.

The defendants in this case were the United States of America, the U.S. Department of Health and Human Services (HHS), Alex Azar, in his capacity as the Secretary of HHS, and David J. Kautter, in his capacity as the Acting Commissioner of the Internal Revenue Service (IRS). 16 states and the District of Columbia intervened as additional defendants.

In order to properly understand the district court’s ruling, it is necessary to revisit the Supreme Court’s 2012 decision on the constitutionality of the ACA, National Federal of Independent Business v. Sebelius (NFIB). In that case, 26 states, along with several individuals and a business organization challenged the ACA’s Individual Mandate and Medicaid expansion provisions as exceeding Congress’ enumerated powers. In a complicated decision, the majority of Justices ruled that the Individual Mandate was unconstitutional under Congress’ authority to regulate interstate commerce, but that the provision could be salvaged under Congress’ authority to lay and collect taxes. In reaching this conclusion, the majority of Justices focused on the “shared responsibility payment” aspect of the Individual Mandate, which imposed a tax on those individuals that failed to purchase or otherwise obtain qualifying health insurance. The majority of Justices concluded that the shared responsibility payment was a “tax.” It was therefore constitutional under the Congress’ general taxing authority.

In sum, the Supreme Court ruled that Congress lacked the power to compel individuals to buy qualifying health insurance, but that it could constitutionally impose a tax on those that failed to purchase or otherwise obtain qualifying health insurance.

In the current case, the court was asked to reconsider the Individual Mandate in light of the TCJA, which “zeroed” out of the shared responsibility payment, effective January 1, 2019. The plaintiffs argued that the Individual Mandate could no longer be justified as a valid exercise of Congress’ taxing authority. The federal government and its agents did not necessarily contest the plaintiffs’ argument with respect to the Individual Mandate. By contrast, the intervening states and the District of Columbia argued that the Individual Mandate could continue to be construed as a tax because it continues to satisfy the factors set forth by the Supreme Court in NFIB.

Judge O’Connor sided with the plaintiffs, holding that, because the Individual Mandate would no longer trigger a tax beginning in 2019, the Supreme Court’s ruling on this point in NFIB was no longer applicable. He therefore concluded that the Individual Mandate could no longer be upheld under Congress’ taxing authority. Judge O’Connor then fell back on the Supreme Court’s previous holding that the Individual Mandate, as a stand-alone command, remained unconstitutional under the Interstate Commerce Clause. Judge O’Connor then ruled that the Individual Mandate could not be severed from the rest of the ACA. On this point, the judge cited the express provisions of the ACA, as well as the Supreme Court’s decisions in NFIB and King v. Burwell.

What this decision means

On its face, the decision strikes down the Affordable Care Act in its entirety. However, the ruling is likely to be appealed to the Fifth Circuit Court of Appeals. Most legal experts expect that, regardless of the decision at the Circuit Court, the case is likely to make its way up to the Supreme Court.

Pending the resolution of these appeals, the Administration has adopted a “business as usual” approach. The White House has already indicated that it will not attempt to enforce the ruling during the appeals process. CMS Administrator Seema Verma recently tweeted that the decision will have “no impact to current coverage or coverage in a 2019 plan.”

The American Ambulance Association will continue to monitor this case as it makes its way through the appeals process, and we will notify our members of any new developments.

CMS Posts 2019 Public Use File

On November 28, 2018, CMS posted the 2019 Ambulance Fee Schedule Public Use Files. These files contain the amounts that will be allowed by Medicare in calendar year 2019 for the various levels of ambulance service and mileage. These allowables reflect a 2.3% inflation adjustment over the 2018 rates.

The 2019 Ambulance Fee Schedule Public Use File can be downloaded from the CMS website by clicking here.

Unfortunately, CMS has elected in recent years to release its Public Use Files without state and payment locality headings. As a result, in order to look up the rates in your service area, you would need to know the CMS contract number assigned to your state. This is not something the typical ambulance service would necessarily have on hand. For this reason, the AAA. has created a reformatted version of the CMS Medicare Ambulance Fee Schedule, which includes the state and payment locality headings. Members can access this reformatted fee schedule here.

View Reformatted Fee Schedule

CMS Announces 2019 Ambulance Inflation Factor

On November 30, 2018, CMS issued Transmittal 4172 (Change Request 11031), which announced the Medicare Ambulance Inflation Factor (AIF) for calendar year 2019.

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 2018, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased 2.9%. CMS further indicated that the CY 2019 MFP will be 0.6%. Accordingly, CMS indicated that the Ambulance Inflation Factor for calendar year 2019 will be 2.3%.

Update on Opioid Legislation & Rural EMS Grant Program

The AAA continues to push on policy issues important to our members we are happy to provide an update on two pieces of legislation that we have been actively monitoring. Congress is proceeding with consideration of several legislative vehicles as they address key topics prior to the November elections.

First Responder Opioid Grant Program

The AAA is pleased to report that language we supported on grant funding for opioid protection training for first responders has passed the Senate. Based on an analysis by counsel, we believe all ambulance service agencies would be eligible to apply for the grants.

In 2017, the Administration officially labeled the Opioid Crisis as a public health emergency, and in response Congress has finally taken action. On Monday, the Senate overwhelmingly passed the Opioid Crisis Response Act with a bipartisan vote of 99-1. The impact of this legislation on the ambulance industry includes providing resources and training so that first responders and other key community sectors, including emergency medical services agencies, can appropriately protect themselves from exposure to drugs such as fentanyl, carfentanil and other dangerous licit and illicit drugs. $36,000,000 will be given annually for each fiscal year from 2019 through 2023. The bill also gives $10,000,000 in supplemental competitive grants to areas that have a record of high seizure of fentanyl to be used toward training of law enforcement and other first responders on how best to handle fentanyl as well as to purchase protective equipment, including overdose reversal drugs.

Lastly, the legislation allows the Department of Labor to award grants to states that have been heavily impacted by the opioid crisis in order to assist local workforce boards and local partnerships in closing the gaps in the workforce for mental health care and substance use disorder. Counsel has provided us with an analysis that all types of ambulance service organizations would be eligible for the described grants. While this legislation is not a solution to every aspect of the opioid crisis our country is currently experiencing, it is an important first step in providing resources to the ambulance industry and others to help combat this public health emergency.

Rural EMS Grant Program

The AAA is diligently working on amending the SIREN Act (S. 2830H.R. 5429) which would reauthorize the Rural EMS Grant program. In an effort to ensure the funding would go to the most needy, small, and rural EMS providers, the language of the SIREN Act would change the eligibility to just governmental and non-profit EMS agencies. Therefore, small rural for-profit ambulance service providers would no longer be eligible to apply for grants. The AAA will continue to work to ensure that all provider types will be able to apply for these grants.

Language similar to the SIREN Act has been included in the Farm Bill (S. 3042/ H.R. 2) that passed both the House and Senate. The Farm Bill is now in Conference Committee between the House and Senate to reconcile differences before final passage. Over the past weeks, the AAA has been pressing Senator Durbin as well as other co-sponsors and Farm Bill conferees to revise the language to ensure small rural for-profit providers would still be able to apply for grants. Our team has met with all co-sponsors of the House and Senate SIREN Act Bills as well as members of the Farm Bill Conference Committee to ensure that they are well informed of the impact this legislation will have on their local providers.

The AAA team has also been conducting targeted outreach to AAA members asking them to get involved by contacting their Members of Congress, especially those on the Conference Committee. It is important for Congress to hear that grants like this one, should be open to all provider types. We thank those members who have already sent letters to their representatives. With Congress trying to wrap up the Farm Bill by the end of September – although looking unlikley, the AAA is pushing hard to change the current language and make sure that all providers might have access to these grants once they are reauthorized.

The AAA will continue to keep you updated on any new developments.

Preliminary Calculation of 2019 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 2018, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 2.87%.

CMS has yet to release its estimate for the MFP in calendar year 2019. However, assuming CMS’ projections for the MFP are similar to last year’s projections, the number is likely to be in the 0.5% range.

Accordingly, the AAA is currently projecting that the 2019 Ambulance Inflation Factor will be approximately 2.4%. 

Cautionary Note Regarding these Estimates

Members should be advised that the BLS’ calculations of the CPI-U are preliminary, and may be subject to later adjustment. The AAA further cautions members that CMS has not officially announced the MFP for CY 2019. Therefore, it is possible that these numbers may change. The AAA will notify members once CMS issues a transmittal setting forth the official 2019 Ambulance Inflation Factor.

2019 Midwest EMS Expo Call for Speakers

2019 Midwest EMS Expo
April 25—26, 2019 | Bloomington, MN

We are asking those individuals interested in presenting at the 2019 Midwest EMS Expo to please submit a session proposal.

  • Submissions for the 2019 conference are due November 1, 2018
  • Midwest EMS Expo speakers are NOT compensated, but do receive a complimentary full conference registration
  • Please submit no more than three proposals
  • To view the 2018 agenda sessions as examples, please visit the agenda page and click on May 2 or 3.

Session Proposal Form 

If you have any questions please contact Meghan Winesett at mwinesett@ambulance.org or (703) 610-0228.

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