Tag: 2020

Speak at Annual 2020!

AAA 2020 Session Proposals due January 31, 2020
November 2–4, 2020
MGM Grand | Las Vegas, Nevada

The American Ambulance Association Annual Conference & Trade Show brings together mobile healthcare leaders from across the country to learn, network, and plan for the future of our industry. AAA Annual is committed to empowering our participants with the insights and best practices they need to serve their patients as well as operate efficiently and profitably.

Speaking at AAA 2020 is your opportunity to share best practices and insights with your peers as you build your personal brand. We invite you to submit your session proposals before January 31, 2020.

Topics

Sample speaking proposal topics considered for AAA 2020 include, but are not limited to:

  • Recruitment, Retention, and Human Resources
  • Operations, Risk Management and Safety
  • Management and Supervision
  • Leadership Development & Structure
  • Improved Fleet Maintenance/Management
  • Clinical/Quality Assurance Program
  • Reimbursement/Patient Accounts
  • Innovation, Technology, and Communications
  • Emerging Healthcare Trends/Hot Topics
  • Healthcare Reform/Public Health

Session Formats & Lengths

In 2020, AAA is focused on engaging attendees interactively in every session. This year, we are seeking submissions in the following formats:

  • 15 Minute Quick Take (similar to TED Talks)
  • 50 Minute Sunrise Session (Early morning energizers. These could be a walking session, yoga gathering, coffee-shop meetup, or another creative idea you have to get the day started off right!)
  • 50 Minute Lecture or Panel (traditional conference formats)
  • 60 Minute Interactive Session (Format ideas to get you thinking.)

Sessions may be either classroom style or set for small workgroups. Audience involvement is encouraged.

Compensation

Please be advised that participation as a presenter is strictly on a voluntary basis. AAA is unable to pay speaker fees or travel and lodging expenses. However, speakers selected for 50 and 60 minute sessions will receive ONE complimentary speaker registration

Proposal Instructions

ALL proposals must be submitted through our online form below by January 31, 2020. AAA is unfortunately unable to consider proposals received after the deadline. Applicants may submit up to three session proposals.

Thank you for your interest in lending your time and talent to the American Ambulance Association’s members. We look forward to reviewing your proposal!

January Law Changes– OR, NJ, NY, NV

Oregon Pregnancy Accommodations Law

 

Following many other states, the new law prohibits employers from deny employment opportunities to applicants or employees who need reasonable accommodations due to or related to their pregnancy or childbirth. 

New Jersey Pay Inquiry Restrictions

 

This law prohibits screening candidates based upon an applicant’s prior wage history. It is also illegal to establish a job candidate’s salary or benefits compensation based upon their prior salary or wage history.

New York Pay Inquiry Restrictions

 

This law prohibits all employers from inquiring about a job candidate’s wage history or relying on prior wage levels in establishing compensation or benefits.

Nevada Pre-Employment Marijuana Testing Restrictions

 

This law exempts employees who are firefighters, EMTs or who operate motor vehicles during the course of their duties.  While this would eliminate many positions within an EMS agency.  EMS employers who are not Federal Contractors or Grantees, need to heed these restrictions for those positions within their organization that do not fit into one of the exempt positions below.

Proposed Rule Impacts Employer Sponsored Health Plans

proposed rule published on November 27th by the IRS, U.S. DOL, and HHS would place new requirements on group health plans and health insurance providers. The rule would require providers to disclose cost-sharing information to participants, beneficiaries, and other covered individuals which would outline their liability to pay certain cost-sharing amounts and out-of-pocket expenses. This rule is part of a Trump Administration effort to foster competition among insurers and healthcare providers in the marketplace. An article published by the Society for Human Resources Management (SHRM) outlines the concerns many employers have regarding the costs associated with implementing the requirements of the proposed rule. These requirements include providing plan enrollees with an online self-service portal where they can see these cost-sharing amounts, as well as require greater collaboration between third party plan administrators, pharmacy benefit managers, and other specialty providers to ensure the accurate disclosure of enrollee financial obligations. Comments on the proposed rule are due by January 14, 2020.

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%.

CMS Announces Comment Period for National Expansion of Prior Authorization Process

On October 29, 2019, the Centers for Medicare and Medicaid Services (CMS) posted a notice in the Federal Register announcing an opportunity for the public to provide comments on the proposed national expansion of the prior authorization process for repetitive, scheduled non-emergent ground ambulance transportation.  CMS refers to this process as its “RSNAT Prior Authorization Model.”  The CMS Notice can be viewed in its entirety at: https://www.govinfo.gov/content/pkg/FR-2019-10-29/pdf/2019-23584.pdf.

Under the Paperwork Reduction Act of 1995, federal agencies are required to publish a notice in the Federal Register concerning each proposed collection of information, and to allow 60 days for the public to comment on the proposed action.  Interested parties are encouraged to provide comments regarding the agency’s burden estimates and other aspects of the proposed collection of information, including the necessity and utility of the proposed information for the proper performance of the agency’s functions, and ways in which the collection of such information can be enhanced.

In this instance, CMS is indicating that it is pursuing approval to potentially expand the existing RSNAT Prior Authorization Model nationwide.  Currently, the RSNAT Prior Authorization Model is in place in 8 states (DE, MD, NJ, NC, PA, SC, VA, and WV) and the District of Columbia.  National expansion is contingent upon CMS’ determination that certain expansion criteria have been met.  CMS is indicating that if the decision is made to expand the program, such expansion may occur in multiple phases.  CMS intends to use the information collected pursuant to this notice to determine the proper payment for repetitive scheduled non-emergent ambulance transportation.

In plain English, CMS is soliciting comments from stakeholders as to the efficacy of the current process, including whether the existing paperwork requirements are sufficient to ensure that approved patients meet the medical necessity requirements for an ambulance.  CMS is also seeking suggestions for how to best expand the program nationally, e.g., whether it makes sense to expand the program in phases, etc.

The AAA Medicare Regulatory Committee has been monitoring the current model for several years.  As a result, the AAA is in a good position to provide constructive feedback to CMS regarding the potential national expansion of the RSNAT Prior Authorization Model.  These suggestions will be included in the AAA’s comment letter.  The AAA also encourages members to offer their own comments.  The AAA anticipates providing members with a sample comment letter in early December that members can use to submit their own comments.

To be considered, comments must be submitted no later than 5 p.m. on December 30, 2019.  Comments may be submitted electronically by going to: http://www.regulations.gov.  Commenters would then need to click the link for “Comment or Submission,” and follow the instructions from there.  Comments may also be submitted by regular mail to the following address: CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention: Document Identifier: CMS-10708, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850.

Submit Comments on Ambulance Data Collection System

Yesterday, the AAA submitted our comment letter to the proposed rule on changes for FY2020 to the Medicare ambulance fee schedule. The comment letter focused on the section of the proposed rule on the ambulance data collection system. For a copy of the detailed 28-page comment letter, please click here.

Read the AAA Comment Letter

The AAA is very pleased with the approach CMS is taking on data collection which is consistent with the intent of the Congress and the methodology developed and advocated by the AAA. While the AAA comment letter is extremely detailed, our only concern is CMS was not able to test or pilot the sampling methodology and data collection instrument prior to inclusion in the proposed rule. Testing would have allowed CMS to fine-tune the survey and may impact the quality of the first year of data.

Now, it is important that AAA members submit their own letters to demonstrate support for the AAA letter and its key points.

AAA members should go to www.regulations.gov and make three points as follows:

  • Our organization supports the approach CMS is proposing to collect ambulance data and we thank CMS and its contractors.
  • Since CMS was unable to test the sampling methodology and data collection tool, we are concerned about the potential quality of the first year of data. We therefore ask CMS to begin education of ambulance service suppliers and providers and work with the American Ambulance Association to adjust the methodology and tool, if necessary, for future data collections.
  • We fully support the specific comments submitted by the American Ambulance Association as to recommended improvements to the data collection tool.

All you need to do is click on www.regulations.gov and include the above three points. Add your first and last name and click “continue” to then finalize your submission.

The AAA has also developed a sample comment letter you can access by clicking here. Go to www.regulations.gov and instead of adding the three points in the comment back, upload your letter.  Please draft your own customized letter using the letter provided by the AAA as a guideline.

Sample Comment Letter

Comments are due by 5:00 pm on Friday, September 27, so please submit your comment letter today! Please also feel free to forward this email to state ambulance associations and other ambulance service organizations.

The AAA will be submitting a second letter in the next week just on seeking clarification around changes to PCS requirements in the proposed rule but will not be asking members to submit similar comments.

We greatly appreciate the work of CMS and its contractors in developing the ambulance data collection system.

Thank you in advance to all of you who take the time to submit comment letters.

Questions?: Contact Us:

If you have questions about the legislation or regulatory 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

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

Thank you for your continued membership and support.

CMS Announces Extension of Prior Authorization Program

On September 16, 2019, CMS published a notice in the Federal Register that it would be extending the prior authorization demonstration project for another year. The extension is limited to those states where prior authorization was in effect for calendar year 2019. The affected states are Delaware, Maryland, New Jersey, North Carolina, Pennsylvania, South Carolina, Virginia and West Virginia, as well as the District of Columbia. The extension will run through December 1, 2020. 

In its notice, CMS indicated that the prior authorization demonstration project is being extended “while we continue to work towards nationwide expansion.”  This strongly suggests that CMS believes the program has met the statutory requirements for nationwide expansion under the Medicare Access and CHIP Reauthorization Act of 2015.  However, CMS indicated that it would use the additional year to continue to test whether prior authorization helps reduce expenditures, while maintaining or improving the quality of care offered to Medicare beneficiaries.

CMS has also updated its CMS Ambulance Prior Authorization webpage to reflect the expansion of prior authorization in the existing states through December 1, 2020.

Preliminary Calculation of 2020 Ambulance Inflation Update

Section 1834(l)(3)(B) of the Social Security Act mandates that the Medicare Ambulance Fee Schedule be updated each year to reflect inflation. This update is referred to as the “Ambulance Inflation Factor” or “AIF”.

The AIF is calculated by measuring the increase in the consumer price index for all urban consumers (CPI-U) for the 12-month period ending with June of the previous year. Starting in calendar year 2011, the change in the CPI-U is now reduced by a so-called “productivity adjustment”, which is equal to the 10-year moving average of changes in the economy-wide private nonfarm business multi-factor productivity index (MFP). The MFP reduction may result in a negative AIF for any calendar year. The resulting AIF is then added to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.

For the 12-month period ending in June 2019, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 1.65%.

CMS has yet to release its estimate for the MFP in calendar year 2020. However, assuming CMS’ projections for the MFP are similar to last year’s projections, the number is likely to be in the 0.6% range.

Accordingly, the AAA is currently projecting that the 2020 Ambulance Inflation Factor will be approximately 1.1%. 

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 2020. Therefore, it is possible that these numbers may change. The AAA will notify members once CMS issues a transmittal setting forth the official 2020 Ambulance Inflation Factor.

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”