AAA Releases 2024 Medicare Rate Calculator
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Tag: Centers for Medicare and Medicaid Services (CMS)
CMS Announces 2024 Ambulance Inflation Factor
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CMS Finalized CY 2024 Ambulance Fee Schedule Add-Ons and Adopts Helpful Modifications to Ground Ambulance Data Collection System
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Impact of Partial Government Shutdown on Healthcare
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AAA Encourages CMS to Consider Revised Innovation Model for Treatment in Place
Washington, DC— While the Centers for Medicare & Medicaid Services (CMS) has decided to end the Emergency Triage, Treat, and Transport (ET3) Model two years early on December 31, 2023, the American Ambulance Association (AAA) remains committed to working with CMS on all future efforts to design programs that fully utilize the ground ambulance services in the delivery of mobile healthcare services. CMS made the decision to end the model “due to lower than expected participation and lower than projected interventions.”
The AAA is encouraged that CMS has stated that, “the lessons learned from the ET3 Model can aid in the development of potential future initiatives.” Our members are committed to supporting such future efforts to make sure that the requirements support true treatment in place and recognize the unique needs of rural ground ambulance services and the communities they serve. Moreover, we encourage CMS to work with the AAA to move forward with alternative destination as a permanent policy based not only on the lessons learned from the ET3 model, but also those garnered as a result of the Public Health Emergency (PHE) waiver. The AAA continues to support efforts to refine the Medicare ground ambulance emergency benefit to support delivering pre-hospital services to the patients who need them at the time they need them and where they need them.
CMS Releases Advance Copy of CY 2024 Physician Fee Schedule Proposed Rule
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7/27 CMS Ambulance Open Door Forum
From CMS on July 19, 2023
The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, July 27, 2023
Start Time: 2:00pm-3:00pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
- Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
Announcements & Updates
- Ground Ambulance & Patient Billing Advisory Committee Meeting Announcement
- Update on Emergency Triage, Treat, and Transport (ET3) Model
- Medicare Ground Ambulance Data Collection System (GADCS): Proposed Changes in the CY 2024 Physician Fee Schedule Proposed Rule
- Slide presentation will be available at: https://www.cms.gov/
medicare/ambulance-fee- schedule-zip-code-files/ ambulance-events
- Slide presentation will be available at: https://www.cms.gov/
- Consolidated Appropriations Act, 2023: Division FF, section 4103: Extension of Add-On Payments for Ambulance Services
III. Open Q&A
**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
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This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.
NEW and UPDATED Open Door Forum Participation Instructions:
This call will be a Zoom webinar with registration and login instructions below.
Register in advance for this webinar:
https://cms.zoomgov.com/
Webinar ID: 161 099 7532
Passcode: 131371
After registering, you will receive a confirmation email containing information about joining the webinar. You may also add the webinar to your calendar using the drop-down arrow on the “Webinar Registration Approved” webpage after registering. Although the ODFs are now a Zoom webinar, we will only use the audio function, no need for cameras to be on.
For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/
Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. The webinar recording and transcript will be posted to: https://www.cms.gov/Outreach-
CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.
GADCS Submission Notices
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CMMI Notice of Termination of the Emergency Triage, Treat, and Transport Model
The Centers for Medicare & Medicaid Innovation (CMMI) has announced the agency will end the ET3 Model pilot program early, on December 31, 2023, which is two years prior to the ET3 Model Participation Agreement’s original Performance Period end date. CMS has been reaching out to ambulance services participating in the program notifying them of the early termination. Please find the notice being sent to participants linked below.
Notice of Early Termination of the ET3 Model
CMS | Updates to Coverage for COVID-19 Tests
The COVID-19 Public Health Emergency is to end on May 11, 2023. The ending of the Public Health Emergency may impact an individual’s coverage of COVID-19 tests. We encourage you to know these changes and share the New Consumer Fact Sheet on COVID-19 tests.
Consumer Fact Sheets:
- English – https://www.cms.gov/files/
document/covid-over-counter- test-coverage.pdf - Spanish – https://www.cms.gov/files/
document/covid-over-counter- test-coverage-spanish.pdf
Before May 11, 2023
If you have any type of health insurance, you can get up to eight over-the-counter tests per month with no out-of-pocket costs. Over-the-counter tests are available in most pharmacies and may also be available online for delivery.
After May 11, 2023
Laboratory tests for COVID-19 that are ordered by your provider will still be covered with no out-of-pocket costs for people with Medicare. Over-the-counter tests will still be available, but there may be out-of-pocket costs. Coverage of over-the-counter tests may vary by your insurance type, as described below.
What does this mean for Medicare Beneficiaries?
Generally, Medicare doesn’t cover or pay for over-the counter products. The demonstration that has allowed us to offer coverage for COVID-19 over-the-counter tests at no cost ends on May 11, 2023.
However, if you are enrolled in Medicare Part B, you will continue to have coverage with no out-of-pocket costs for appropriate laboratory-based COVID-19 PCR and antigen tests, when a provider orders them (such as drive-through PCR and antigen testing or testing in a provider’s office).
If you are enrolled in a Medicare Advantage plan, you may have more access to tests depending on your benefits. Check with your plan.
What does this mean for people with Medicaid or Children’s Health Insurance Program?
If you have coverage through Medicaid or the Children’s Health Insurance Program, you will have access to COVID-19 over-the-counter and laboratory testing through September 30, 2024. After that date, coverage of testing may vary by state.
What does this mean for people with Private Insurance?
If you have private insurance, coverage will vary depending on your health plan. However, private plans won’t be required by federal law to cover over-the counter and laboratory-based COVID-19 tests after
May 11, 2023. If your insurance chooses to cover COVID-19 testing, they may require cost sharing, prior authorization, or other forms of medical management.
Impact of Expiration of Public Health Emergency on May 11, 2023
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Summary: CMS Ambulance Open Door Forum
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3/16 | CMS Ambulance Open Door Forum
The next CMS Ambulance Open Door Forum scheduled for:
Thursday, March 16, 2023
2:00pm-3:00pm PM Eastern Time (ET);
This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849
Conference Leaders: Jill Darling, Maria Durham
**This Agenda is Subject to Change**
I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)
II. Announcements & Updates
• Medicare Ground Ambulance Data Collection System
(GADCS): Top 5 Tips for Selected Organizations in Year 1, 2, 3, and 4
Slide presentation will be available on CMS’ Ambulances
Services Center website: https://www.cms.gov/medicare/ambulance-fee-schedule-zipcode-files/ambulance-events
Please see the following information regarding COVID-19
PHE Updated Guidance for Ambulance Organizations:
Public Health Emergency (PHE) 1135 Waivers: Updated
Guidance for Providers
III. Open Q&A
**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
———————————————————————
This Open Door Forum is open to everyone, but if you are a member of the Press,
you may listen in but please refrain from asking questions during the Q & A portion of
the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank
you.
Open Door Participation Instructions:
This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849
Persons participating by phone do not need to RSVP. TTY Communications Relay
Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-
800-855-2880. A Relay Communications Assistant will help.
Instant Replay: 1-800-814-6745; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
800-814-6745 and entering the Conference Passcode beginning 1 hours after the call
has ended. The recording is available until March 18, 2023, 11:59PM ET.
For ODF schedule updates and E-Mailing List registration, visit our website at
http://www.cms.gov/OpenDoorForums/.
Were you unable to attend the recent Ambulance ODF call? We encourage you to
visit our CMS Podcasts and Transcript webpage where you can listen and view the
most recent Ambulance ODF call. The audio and transcript will be posted to:
https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.
CMS provides free auxiliary aids and services including information in accessible
formats. Click here for more information. This will point partners to our CMS.gov
version of the “Accessibility & Nondiscrimination notice” page. Thank you.
CMS Releases New Guidance on Ending of the COVID-19 PHE
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CMS Webinar on Addressing Healthcare Inequities
Ambulance Medicare Add-Ons Extended to 2024
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CMS Publishes New EMTALA Training Materials
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AAA Posts Reformatted 2023 Public Use File
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CMS Posts 2023 Public Use File
On November 23, 2022, CMS posted the 2023 Ambulance Fee Schedule Public Use Files. These files contain the amounts that will be allowed by Medicare in the calendar year 2023 for the various levels of ambulance service and mileage. These allowable reflect an 8.7% inflation adjustment over the calendar 2022 rates. The 2023 Ambulance Fee Schedule Public Use File can be downloaded from the CMS website by clicking here.
Please note that these files reflect the Medicare allowable based on current federal law. Accordingly, the 2023 Public Use Files do not include the current add-ons (i.e., 2% for urban, 3% for rural, and the super-rural bonus), as these add-ons are currently scheduled to expire on December 31, 2022.
The AAA is actively working with congressional offices to not only extend but hopefully increase, the Medicare ambulance add-ons by the end of the year. If you have not already written to your members of Congress about extending the add-ons at increased levels, please do so today by using the AAA online advocacy tool by clicking here.
Unfortunately, in recent years, CMS has elected 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 will be publishing a reformatted version of the CMS Medicare Ambulance Fee Schedule that includes the state and payment locality headings. The reformatted fee schedule will be available on the AAA website in the coming days.
The AAA will also be publishing an updated version of its Medicare Rate Calculator, which we expect to have available on our website once we have a better sense of the timing of the extension of the add-ons.
CMS Update-CY 2023 Final Ambulance Fee Schedule
Member Advisory: CMS Issues CY 2023 Final Ambulance Fee Schedule Rule Updated Data Ground Ambulance Data Collection System
by Kathy Lester, JD, MPH
CMS has released the “CY 2023 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicare and Medicaid Provider Enrollment Policies, Including for Skilled Nursing Facilities; Conditions of Payment for Suppliers of Durable Medicaid Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS); and Implementing Requirements for Manufacturers of Certain Single-dose Container or Single-use Package Drugs to Provide Refunds with Respect to Discarded Amounts” (Final Rule). The Final Rule includes proposals affecting ground ambulance services in terms of medical necessity requirements and documentation requirements, as well as to the ground ambulance cost collecting tool.
I. Medical Necessity and Documentation Requirements for Nonemergency, Scheduled, Repetitive Ambulance Services
CMS finalizes the modifications to the documentation requirements codified in regulation pertaining to the medical necessity and documentation requirements for nonemergency, scheduled, repetitive ambulance services, such as those to/from dialysis facilities. The Final Rule clarifies that the Physician Certification Statement (PCS), and additional documentation from the beneficiary’s medical record, may be used to support a claim that transportation by ground ambulance is medically necessary. It also notes that the PCS and additional documentation must provide detailed explanations that: (1) are consistent with the beneficiary’s current medical condition; and (2) explain the beneficiary’s need for transport by an ambulance. Coverage includes observation or other services rendered by qualified ambulance personnel. It maintains the following requirements:
- In all cases, the provider or supplier must keep appropriate documentation on file and, upon request, present it to CMS;
- The ambulance service must meet all program coverage criteria including vehicle and staffing requirements; and
- A signed PCS does not alone demonstrate that transportation by ground ambulance was medically necessary.
CMS declines to “confine this regulatory clarification to the RSNAT prior authorization program, as there may be non-emergent, scheduled, repetitive ambulance transport services outside of that program that would be affected.” (Display Copy 1756) CMS also does not provide further clarification about what it means by the term “additional documentation” because it believes that “the data elements needed will vary depending upon the beneficiary’s specific conditions and needs.” (Id.) CMS also states that “[t]his proposal does not establish new obligations for documentation; rather, it merely clarifies existing requirements.” (Id. at 1757). In response to a comment, CMS also writes, “In addition, our pre-proposal language and proposed regulatory language both reflect that the presence of a PCS alone is not sufficient to demonstrate medical necessity, and, therefore, must be supported by medical documentation.” (Id.) CMS also declined to extend authorization to nurse practitioners and physicians’ assistants, stating that to do so would be outside of the scope of the rule.
II. Ground Ambulance Data Collection Instrument
CMS finalizes the proposed changes to the ground ambulance data collection instrument and instructions with a few additional modifications in response to comments. They fall within four areas: (1) editorial changes for clarity and consistency; (2) updates to reflect the web-based system; (3) clarifications responding to feedback from questions from interested parties and testing; and (4) typos and technical corrections. The updated instrument that includes all of the CY 2023 proposed changes to review and provide comments on is posted on the CMS website at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AmbulanceFeeSchedule/Downloads/Medicare-Ground-Ambulance-Data-Collection-System-Instrument.pdf.
One of these modification is to Section 5, Question 3c, which now reads: Does your organization respond to calls with another non- transporting agency such as a local fire department that is not part of your organization? After the question, the following instructions will be provided: This includes joint responses with other ground ambulance organizations as well as cases where a fire, police, or other public safety department responses to calls for service with your organization. Only consider cases where your ground ambulance does or would have transported the patient, if necessary.
The Final Rule notes that the system already includes an “autosave” feature that saves responses as they are entered. The system also allows the same user to enter information at different times, and/or multiple users to enter information at different times. The system also already includes many validation and error checking steps that are automatically applied as respondents enter information. CMS also noted that it has no plans to adopt additional import functionality prior to the launch of the system, but that it will continue to explore the option of an API. CMS also indicates that the final written tool and web-based platform will align before the system goes live. A print function will also be available for the online submissions.
CMS indicates that the data from the collection system will be made available to the public through posting on the CMS website at least every 2 years. Summary results will be posted by the last quarter. The data collected under the ground ambulance data collection system will be publicly available beginning in 2024.
CMS also indicates that it will not require a ground ambulance organization to fill the data entry submitter and data certifier roles with different individuals.
CMS has also provided additional guidance, including FAQs available at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/AmbulanceFeeSchedule/Downloads/Medicare-Ground-Ambulance-FAQs.pdf.
CMS also finalizes its proposal for an automated process for submitting a hardship exemption request and informal review request.
III. Origin and Destination Requirements Under the Ambulance Fee Schedule
In the Final Rule, CMS also responds to comments it received on the Interim Final Rule that expanded the origin and destination requirements. It finalizes the interim final policy that the expanded list of covered destinations for ground ambulance transports including, but are not limited to, any location that is an alternative site determined to be part of a hospital, CAH or SNF, community mental health centers, FQHCs, RHCs, physician offices, urgent care facilities, ASCs, any location furnishing dialysis services outside of an ESRD facility when an ESRD facility is not available, and the beneficiary’s home. The policy will be In effect for the duration of the PHE for the COVID-19 only.
