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Tag: Balance Billing

RFP | State EMS Policy Whitepaper & Strategic Consulting

Request for Proposal

State EMS Policy Whitepaper Development & Strategic Consulting Services

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Overview and Objectives

The American Ambulance Association (AAA) seeks proposals from qualified consulting firms to provide strategic services in the field of ambulance and emergency medical services. The selected firm will work collaboratively with the Association to identify opportunities, analyze state landscapes, develop policy recommendations, and manage the project efficiently.

About the American Ambulance Association

Caring for People—First.
The American Ambulance Association safeguards the future of mobile healthcare through advocacy, thought leadership, and education. AAA advances sustainable EMS policy, empowering our members to serve their communities with high-quality on-demand healthcare. For more than 40 years, we have proudly represented those who care for people first. AAA’s 1500+ organizational members serve cities and counties in all 50 states.

Scope of Services

The consulting firm shall provide the following services:

  • Planning and Strategy Session: Convene a strategy session with key AAA leaders to prioritize states for research and opportunity development.
  • State Landscape Research and Analysis: Conduct comprehensive research and analysis for no fewer than ten states, focusing on:
    • State statutes, regulations, and Medicaid policies for ambulance services.
    • Medicaid fee schedules for ambulance services.
    • State policies on balance billing and treatment in place.
    • Initiatives addressing ambulance workforce shortage, including the use of grants and ARPA funds, with a particular focus on availability or potential availability for non-governmental EMS providers.
  • Policy Recommendation Development: Collaborate with AAA to develop in-depth state-level policy recommendations on the topics of EMS workforce recruitment and retention, balance billing, and treatment in place.
  • Whitepaper Development: Write, edit, and publish no fewer than three in-depth whitepapers focused on state-level EMS recruitment and retention, balance billing, and treatment in place policy. The whitepapers should be suitable for use by EMS providers and state level legislators and regulators seeking to identify state EMS policy best practices.
  • Project Management & Communication: Provide robust project management, including regular client meetings to review goals and progress during the development of policy recommendations and whitepapers. Facilitate regular coordination and progress review calls and monthly written updates.

All deliverables should be received in calendar year 2024.

Fees and Expenses

Proposals must include a detailed fee structure, including hourly rates for various personnel and any applicable prorated fees. A fixed total or capped amount is strongly preferred over uncapped “time and expenses” billing.

Submission Guidelines

Proposals should be submitted by January 31, 2024 to with the subject line “State EMS Whitepaper Proposal.” Proposals should include a detailed approach to the scope of services, a proposed timeline for deliverable development, detailed qualifications of the team, and a clear fee structure. Submitters should include examples of past work of similar scope in the broader healthcare field.

Selection Criteria

Proposals will be evaluated based on the firm’s experience, approach to the project, team qualifications, and cost-effectiveness. Notification will be delivered by February 29, 2024.



GAO | Roll Out of IDR Process for Out-of-Network Claims Has Been Challenging

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GAO-24-106335Published: Dec 12, 2023. Publicly Released: Dec 12, 2023.

Fast Facts

Individuals with private health insurance can receive “surprise bills” for the difference between what a provider charged and what their insurance paid.

A 2021 law prohibits surprise billing for some services, and directed the Departments of Health and Human Services, Labor, and Treasury to give providers and insurers a forum to resolve disputes about how much insurers should pay for out-of-network care.

But the rollout has been challenging. As of June 2023, over 490,000 disputes have been submitted, a much larger number than anticipated by the agencies.

And 61% of the disputes are unresolved as of June 2023.

A man holding papers while looking at a laptop.


What GAO Found

The No Surprises Act directed the departments of Health and Human Services (HHS), Labor, and Treasury to establish a federal independent dispute resolution process. The process, which was effective April 2022, is a voluntary forum for health care providers and health insurance issuers to resolve disputes about how much should be paid for out-of-network care. The payment determinations are made by certified dispute resolution entities, which serve as arbiters. The Centers for Medicare & Medicaid Services (CMS)—an agency within HHS—administers the independent dispute resolution process.

The three departments reported that parties submitted nearly 490,000 disputes from April 2022 through June 2023. About 61 percent of these disputes remained unresolved as of June 2023. According to officials from the departments, a primary cause of the large number of unresolved disputes is the complexity of determining whether disputes are eligible for the process.

Number of Out-of-Network Disputes in the Federal Independent Dispute Resolution Process by Calendar Quarter, April 15, 2022—June 30, 2023

The groups GAO interviewed described a challenging roll out of the independent dispute resolution process, including a higher-than-expected dispute volume. For example, the departments anticipated about 22,000 disputes in 2022, but received nearly 490,000 through June 2023. Four groups told GAO the departments did not account for the experience of states with similar processes when making the estimate. Disputing parties and certified entities also described the broader effects of those challenges, such as backlogs resulting in delays in payment determinations. The departments have taken some actions to address challenges, such as conducting pre-eligibility reviews on submitted disputes.

To address concerns from insurers and providers, CMS and Labor look into complaints; however, stakeholder groups expressed concern with what they describe as a lack of response to submitted complaints. The departments reported limited ability to increase enforcement efforts due to budget constraints. HHS has requested a budget increase for the process, and the departments are revisiting the administrative fee amount, which is intended to cover the costs of the process, and plan to issue updated program rules.

Why GAO Did This Study

About two thirds of individuals in the United States receive their health coverage through private health plans. Balance billing is when insured patients receive a bill from a health care provider for the difference between the amount charged and the payment received from the health insurance issuer. An unexpected balance bill is referred to as a “surprise bill” and may create a financial strain for patients. For individuals with private health insurance, the No Surprises Act prohibits providers from balance billing in certain circumstances and directed the three departments to establish the federal independent dispute resolution process.

The Consolidated Appropriations Act, 2021, includes a provision for GAO to review the federal independent dispute resolution process. This report describes (1) the number and types of disputes submitted between April 2022 and June 2023, and the status of their resolution; (2) selected stakeholders’ experiences with the process, and agency actions to address challenges; and (3) how federal agencies oversee the process.

GAO reviewed published reports, relevant federal laws, regulations, and guidance; and interviewed officials from CMS and Labor. GAO also interviewed five selected health care providers or their representatives, which accounted for nearly half of all submitted disputes as of December 2022. In addition, GAO interviewed three issuers, three certified entities that arbitrate the disputes, and 10 stakeholder groups.

For more information, contact John E. Dicken at (202) 512-7114 or

PBS NewsHour | The No Surprises Act left out ground ambulances. Here’s what’s happening now


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GAPBAC | Follow Up from Committee Meeting #2

Ground Ambulance and Patient Billing (GAPB) Advisory Committee Public Meeting #2 (August 16, 2023)

The Ground Ambulance and Patient Billing (GAPB) Advisory Committee Second Public Meeting was held on August 16, 2023. Materials for this meeting are available for download on the GAPB website.

As we continue this webinar series, we look to you as industry experts to provide feedback and recommend information that would be beneficial in future webinars. Written public comments for consideration by the Advisory Committee may be emailed to: .

Public comments on the specific topics listed in the GAPB Advisory Committee Public Meeting #2 Agenda, should be submitted by September 5, 2023 for consideration by the GAPB Advisory Committee.


GAPBAC Meeting Postponed

The first meeting (virtual) of the Ground Ambulance and Patient Billing Advisory Committee scheduled for January 17 and 18 has been postponed. According to CMS, the meeting is being postponed due to “operational impediments”. We will let you know the new dates for the meeting when announced by CMS.

AAA President Baird Named to Balance Billing Advisory Committee

The Centers for Medicare & Medicaid Services (CMS) today appointed American Ambulance Association President Shawn Baird to the Ground Ambulance and Patient Billing Advisory Committee (GAPBAC), established by the Congress under “The No Surprises Act.” Shawn will represent the ground ambulance service provider and field personnel community.

 “I am honored to have the opportunity to serve,” stated Baird. “I look forward to representing the interests of EMS providers and professionals as they care for our communities.

 The Congress recognizes that the one-size-fits all approach to addressing surprise medical bills would not work for EMS. State and local governments regulate EMS agencies services and rates, as both first responders and medical care providers, which adds another level of complexity. As a result, the Congress established GAPBAC so the unique characteristics of ground ambulance services could be taken into consideration when evaluating private insurer billing policies to protect access to EMS, respect state and local government regulation, and protect patients.

 Patients with private insurance should not be caught in the middle when their insurers do not adequately reimburse for vital ground ambulance services,” said Baird. “EMS must receive fair reimbursement by insurance companies for providing critical medical services to patients.”

 Baird will bring to the Committee his years of firsthand experience and expertise as a paramedic and operator of an ambulance service in both urban and rural areas. He will also share knowledge gained from his years of volunteer leadership at the American Ambulance Association and the Oregon State Ambulance Association, as well as his term as an appointee to the National EMS Advisory Committee.

 The GAPBAC is charged with “reviewing options to improve the disclosure of charges and fees for ground ambulance services, better inform consumers of insurance options for such services, and protect consumers from balance billing.” The Committee will submit a report that includes recommendations with respect to disclosure of charges and fees for ground ambulance services and insurance coverage, consumer protection and enforcement authorities of the Departments of Labor, Health and Human Services, and the Treasury and State authorities, and the prevention of balance billing to consumers. The report must be received no later than 180 days after the date of its first meeting.

About the American Ambulance Association

The American Ambulance Association safeguards the future of mobile healthcare through advocacy, thought leadership, and education. AAA advances sustainable EMS policy, empowering our members to serve their communities with high-quality on-demand healthcare. For more than 40 years, we have proudly represented those who care for people first.

FAIR Health | Ground Ambulance Services in the United States

From FAIR Health in February 2022

“Currently, no federal law protects consumers against “surprise” bills from out-of-network ground ambulance providers. Some state and local governments regulate ground ambulance surprise billing practices; however, such laws may not apply to all health plans or ambulance providers in an area. Because of the substantial policy interest in ground ambulance services, FAIR Health drew on its vast database of private healthcare claims to illuminate multiple aspects of such services across the nation, including utilization, costs, age, gender, diagnoses and differences across states.”

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