Tag: cost data collection
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.
Centers for Medicare & Medicaid Services Announces Year 3 and Year 4 Medicare Ground Ambulance Data Collection System Selected Providers and Suppliers
The Centers for Medicare & Medicaid Services (CMS) has released the ground ambulance suppliers and providers selected for Years 3 and 4 of the Medicare ground ambulance data collection system. The list of the selected providers and suppliers is available on the CMS website. These providers and suppliers will be asked to collect data during their budget year starting in 2023 and to report the data within five months of the close of that year.
Providers and suppliers who are selected should respond to the notification letter sent by Medicare Administrative Contractors (MAC). Organizations may select a calendar year or fiscal year start date for the data collection period. Data will be submitted for a continuous 12-month period using the Medicare Ground Ambulance Data Collection Instrument: English (PDF).
The AAA continues to provide educational support for ground ambulance services to help them collect and report these data. In addition to in-person sessions, the AAA offers webinars on demand.
It is important that all ground ambulance providers and suppliers collect and report data through this program. The Congress intends to use the information to help reform Medicare ambulance fee schedule.
In late April, CMS will issue a Comparative Billing Report (CBR) on Medicare Part B claims for ambulance ground transport. Use the data-driven report to compare your billing practices with those of peers in your state and across the nation.
CBRs aren’t publicly available. Look for an email from firstname.lastname@example.org to access your report. Update your email address in the Provider Enrollment, Chain, and Ownership System to ensure delivery.
For More Information:
Last night, the United States Senate passed language as part of the FY 2022 Omnibus Appropriations Package that would delay the due date of the Medicare Payment Advisory Committee (MedPAC) report analyzing ambulance cost data. The U.S. House of Representatives had passed the package on Wednesday. The delay in the MedPAC report is a victory for the AAA and our members as we spearheaded efforts for the delay.
We thank Senators Chuck Schumer, Catherine Cortez Masto, Ron Wyden, Mike Crapo and Debbie Stabenow and Representatives Richard Neal, Kevin Brady, Frank Pallone and Catherine McMorris Rogers for championing and assisting with passage of the provision.
The delay in the timing of the MedPAC report was necessary due to CMS postponing the beginning of ambulance cost data collection by two years to account for the COVID-19 pandemic. Even though data collection had been delayed, MedPAC indicated that they were compelled to stick to the statutory deadline of issuing a report – with very little or no new ambulance data – to Congress by March 15, 2023.
With little to no new data, MedPAC would have likely reinstated their recommendations from their 2002 ambulance report which did support most of the temporary ambulance increases but at the cost of cutting BLS non-emergency services by 5.75%. MedPAC had also recommended doing away with rural and super rural increases in favor of a low volume adjuster which would disrupt reimbursement levels for rural providers without having more detailed data if indeed the proper approach.
The language from the FY2022 Omnibus Appropriations Package is as follows:
SEC. 311. REVISION OF THE TIMING OF MEDPAC REPORT ON AMBULANCE COST DATA.
Section 1834(l)(17)(F)(i) of the Social Security Act (42 U.S.C. 1395m(l)(17)(F)(i)) is amended by striking ‘‘Not later than March 15, 2023, and as determined necessary by the Medicare Payment Advisory Commission thereafter’’ and inserting ‘‘Not later than the second June 15th following the date on which the Secretary transmits data for the first representative sample of providers and suppliers of ground ambulance services to the Medicare Payment Advisory Commission, and as determined necessary by such Commission thereafter,’’.
Next week, we will be launching a Call to Action asking AAA members to reach out to their members of Congress to cosponsor the Protecting Access to Ground Ambulance Medical Services Act (H.R. 2454, S. 2037) Medicare Ambulance which would extend the temporary Medicare ambulance increases for five years. The increases expire at the end of this year and the five-year extension is necessary to provide time for the MedPAC report and the Congress to act.
Yesterday, the American Ambulance Association Board of Directors approved the Association’s advocacy priorities for 2022. Our key initiatives reflect the challenges we face this year, including short-sighted threats to EMS balance billing, a worsening workforce shortage, the expiration of the temporary Medicare increases, and potential sequestration cuts.
We also continue to fight for you as you care for people first on the frontlines of the COVID-19 pandemic. We will sustain our efforts at securing additional funding for ground ambulance services to help address the increased costs of providing medical care and transport during the Public Health Emergency.
To achieve our collective goals, the AAA Board will need to mobilize the full voice of influence of the EMS community this year. If you have not already sent an email using the AAA advocacy system to your members of Congress, please do so today!
Staff will be reaching out to you at key points later in the year about letter writing for specific individual policy requests. But it is important that they hear from you now on all the top issues for ground ambulance services. They are:
Top AAA Advocacy Priorities for 2022
EMS Workforce Shortage
With the persistent shortage of ground ambulance service field personnel raising to a crisis level with the COVID-19 pandemic, the AAA moved the issue to a top policy priority. The AAA is currently working with key Congressional Committees of jurisdiction to hold hearings on the EMS workforce shortage. We are also developing legislation to specifically target increasing access for ground ambulance service organizations to federal programs and funding for the retention and training of health care personnel.
The AAA successfully educated the Congress on the role of local government oversight and other unique characteristics of providing ground ambulance service organizations. As a result, the Congress directed the establishment of a Ground Ambulance and Balance Billing Advisory Committee to address the issue. The Committee is in the process of being formed and then has 180 days in which to make recommendations to the Congress. The AAA will be involved with the Committee and advocating that the Congress implement policies that meet the needs of our members.
Additional COVID-19 Financial Assistance
The AAA is advocating for additional financial assistance for ground ambulance service organizations to help address the increased costs of labor and other higher costs associated with providing health care during the COVID-19 pandemic.
Medicare Ambulance Relief
The temporary Medicare ambulance increases of 2% urban, 3% rural and the super rural bonus payment expire at the end of the year. The AAA will continue to push for passage of the provisions of the Preserving Access to Ground Ambulance Medical Services Act (S. 2037, H.R. 2454) before the provisions expire as well as for the adoption of language to ensure truly rural areas remain rural following changes to geographical designations based on the 2020 census.
The Congress delayed the additional 4% sequestration cut for only one yea. The AAA is working with other EMS and health care provider and supplier groups to permanently prevent the cut from going into effect as well as further extending the moratorium on the long-standing 2% cut.
Ambulance Cost Data Collection
With the 2-year delay of ambulance data collection due to the pandemic, the Medicare Payment Advisory Committee (MedPAC) will have little to no data to analyze in March 2023 in which to make recommendations to the Congress on Medicare ambulance payment policy and rates. The AAA is asking the Congress to push back the date of the MedPAC report and also expand the modified data collection timeline of two years to the intended four years.
On behalf of my fellow board members, I again thank you for your continued membership and participation. We look forward to serving you for many years to come.
Should you have any questions regarding our advocacy priorities, please contact AAA Senior Vice President of Government Affairs Tristan North at email@example.com.
Medicare Ground Ambulance Data Collection System Webinar: Question and Answer (Q&A) Session Tuesday, December 14, 2021 | 2:00 PM – 3:00 PM ET
To register for this CMS Zoom webinar:
After registering, you will receive a confirmation email containing information about joining the webinar.
Do you have questions about the Medicare Ground Ambulance Data Collection System? We are holding a live Q&A session on December 14, 2021 at 2:00 pm. Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “December 14 Q&A” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions using the “Q&A” button at the bottom of your Zoom screen. In addition, we will update documents on our Ambulances Services Center webpage with answers to common questions from this session.
For more information, including the list of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 PFS Final Rule, the CY 2020 PFS final rule, and the Bipartisan Budget Act of 2018.
From CMS on October 4, 2021
Dear Ground Ambulance Providers and Suppliers,
Please attend our October 7 webinar and October 12 Q&A session to learn about the Medicare Ground Ambulance Data Collection System. Both events will use Zoom. Starting January 1, 2023, selected ground ambulance organizations are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10% payment reduction.
Medicare Ground Ambulance Data Collection System Webinar: Labor Costs – October 7
Thursday, October 7 from 2-3pm ET
During this webinar, CMS will walk through the Labor Cost section of the Medicare Ground Ambulance Data Collection Instrument (section 7). The presentation includes examples to help different types of ground ambulance organizations understand how to collect and report data for their paid and volunteer staff.
A Q&A session will follow this presentation. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 7 Labor Cost Webinar” in the subject line.
- Ambulances Services Center webpage–includes lists of organizations that must collect data starting in 2022
- CY 2022 Physician Fee Schedule (PFS) proposed rule
- CY 2020 PFS final rule
- Bipartisan Budget Act of 2018
Medicare Ground Ambulance Data Collection System: Q&A Session – October 12
Tuesday, October 12 from 2-3pm ET
Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send your questions in advance to AmbulanceDataCollection@cms.hhs.gov with “October 12 Q&A” in the subject line. We’ll update documents on our Ambulances Services Center webpage with answers to common questions from this session.
Tuesday, September 14 from 2-3 pm ET
CMS is hosting a Q&A session about the Medicare Ground Ambulance Data Collection System tomorrow at 2:00pm Eastern.
Do you have questions about the Medicare Ground Ambulance Data Collection System? Join this live Q&A session. You may also send questions in advance to AmbulanceDataCollection@
- Ambulances Services Center webpage: Includes lists of organizations that must collect data starting in 2022
- Calendar Year (CY) 2022 Physician Fee Schedule (PFS) proposed rule
- CY 2020 PFS final rule
Medicare Ground Ambulance Data Collection System: Question and Answer Session on September 14, 2021 2:00 PM – 3:00 PM ET.
To participate in the Q&A session, you must register for the session at: https://cms.zoomgov.com/webinar/register/WN_tuyiGdvORRiTXbmPaTQ1zg.
After registering, you will receive a confirmation email containing information about joining the webinar.
Do you have questions about the Medicare Ground Ambulance Data Collection System? We are holding a live Q&A session on September 14, 2021 at 2:00 pm. Please send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “September 14 Q&A” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions in the “chat” box. In addition, we will update documents on our Ambulances Services Center webpage with answers to common questions from this session. For more information, including the lists of ground ambulance organizations selected to collect and report information starting in 2022, see the Ambulances Services Center webpage, the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf, and the CY 2020 Physician Fee Schedule final rule.
Medicare Ground Ambulance Data Collection System Webinar: Instrument Walkthrough
Thursday, August 26, 2021 from 2:00 PM-3:30 PM ET.
To register for this webinar: https://cms.zoomgov.com/webinar/register/WN_S0aGs_TWTpWRBWF5hDAf3Q.
After registering, you will receive a confirmation email containing information about joining the webinar.
During this call, CMS will walk through the Medicare Ground Ambulance Data Collection Instrument section-by-section, focusing on select instructions, data collection guidelines, and common questions and answers. The webinar will also highlight proposed changes to the instrument in the CY 2022 Physician Fee Schedule (PFS) Proposed Rule: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf.
A question-and-answer session will follow this presentation. You may send questions in advance to AmbulanceDataCollection@cms.hhs.gov with “August 26 Instrument Webinar” in the subject line. We will answer your questions that you submitted in advance during the call or participants may also submit live questions in the “chat” box.
For more information, including ground ambulance organizations that must report, see the Ambulances Services Center webpage, CY 2020 Physician Fee Schedule final rule, and Bipartisan Budget Act of 2018.
August 12, 2021 Ambulance Open Door Forum
August 12, 2021 | 14:00–15:30 ET
Slide presentation on the Overview of the Medicare Ground Ambulance Data Collection System (PDF) is now available.
The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, August 12, 2021
Start Time: 2:00pm-3:30pm 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**
I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market-based Pricing
Moderator – Jill Darling (Office of Communications)
II. Announcements & Updates
- Emergency Triage, Treat, and Transport (ET3) Model Update
- ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
- ET3Model@cms.hhs.gov for inquiries
- ET3 Model Listserv for Model updates: https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12521
- ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
Overview of the Medicare Ground Ambulance Data Collection
A copy of the presentation will be available on the
Ambulances Services Center website under
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:
August 12, 2021 | 14:00–15:30 ET | Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
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.
1-866-470-7051; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
866-470-7051 and entering the Conference Passcode beginning 1 hours after the
call has ended. The recording is available until August 14, 2021, 11:59PM ET.
For ODF schedule updates and E-Mailing List registration, visit our website at
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. Please allow up to three weeks to get both the
audio and transcript posted to: https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.
Updated CMS FAQs on the Ambulance Data Collection System and Reporting Requirement Delay
As we recently reported, CMS announced that it will be delaying the implementation of the statutorily mandated ambulance data collection system. CMS has released a new set of Frequently Asked Questions (FAQs) clarifying the delay. In sum, ambulance organizations selected to provide cost data for 2020 will now be required to report 2021 data in Year 2. CMS will also add a new set of ambulance organizations for Year 2 reporting as well. This means that twice as many ambulance organizations will be reporting 2021 data in Year 2 and there will be no data reported for 2020. Any organization selected that does not report data will be subject to the 10 percent penalty, unless an exception applies. In addition to addressing concerns about reporting during the pandemic, the FAQs suggest that CMS is concerned that 2020 data “may not be reflective of typical costs and revenue associated with providing ground ambulance services.”
The complete list of these questions, as well as previous ambulance FAQs for COVID-19 on Medicare Fee-for-Service (FFS) Billing can be found here. The new data collections are below.
Data Collection and Reporting Requirements for the Medicare Ground Ambulance Data Collection System
1. Question: CMS requires selected ground ambulance organizations to collect cost, revenue, utilization, and other information through the Medicare Ground Ambulance Data Collection System. The collected information will be provided to MedPAC, which is required to submit a report to Congress on the adequacy of Medicare payment rates for ground ambulance services and geographic variations in the cost of furnishing such services. Will the data collection and reporting requirements for the Medicare Ground Ambulance Data Collection System be delayed due to COVID-19?
Answer: Yes. CMS has issued a blanket waiver: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration- waivers.pdf due to the PHE for the COVID-19 pandemic. CMS is modifying the data collection period and data reporting period, as defined at 42 CFR §414.626(a), for ground ambulance organizations that were selected by CMS to collect data beginning between January 1, 2020, and December 31, 2020 (Year 1).
Under this modification, these ground ambulance organizations can select a new data collection period that begins between January 1, 2021, and December 31, 2021; collect the necessary data during their selected data collection period; and submit the data during the data reporting period that corresponds to their selected data collection period.
CMS is modifying this data collection and reporting period to increase flexibilities for ground ambulance organizations that would otherwise be required to collect data in 2020–2021 so that they can focus on their operations in support of patient care.
As a result of this modification, ground ambulance organizations selected for year 1 data collection and reporting will collect and report data during the same period of time that will apply to ground ambulance organizations selected by CMS under §414.626(c) to collect data beginning between January 1, 2021, and December 31, 2021 (year 2) for purposes of complying with the data reporting requirements described at §414.626.
For additional information on the Medicare Ground Ambulance Data Collection System, please visit the Ambulances Services Center website at
2. Question: Will the 10 percent payment reduction still apply to ground ambulance organizations that are now required to collect and report data under the modified data collection and reporting period but do not sufficiently report the required data?
Answer: Yes. The 10 percent payment reduction described at 42 CFR §414.610(c)(9) will still apply if a ground ambulance organization is selected to collect and report data under the modified data collection and reporting timeframe, but does not sufficiently submit the required data according to the modified timeframe and is not granted a hardship exemption. The payment reduction will be applied to payments made under the Medicare Part B Ambulance Fee Schedule for services furnished during the calendar year that begins following the date that CMS provides written notification that the ground ambulance organization did not submit the required data.
3. Question: The modification states that the ground ambulance organizations that were selected by CMS to collect data beginning between January 1, 2020, and December 31, 2020 (year 1) can select a new continuous 12-month data collection period that begins between January 1, 2021, and December 31, 2021. Do the ground ambulance organizations that were selected in year 1 have an option to continue with their current data collection period that started in early 2020 or choose to select a new data collection period starting in 2021?
Answer: No. The ground ambulance organizations that were selected for year 1 do not have an option and must select a new data collection period that begins in 2021. CMS cannot permit this option because the data collected in 2020 during the PHE may not be reflective of typical costs and revenue associated with providing ground ambulance services. New: 6/16/20
4. Question: Does the guidance mean that there will be no data reporting in 2021 and that both the ground ambulance organizations that were selected for year 1 and the ground ambulance organizations that will be selected for year 2 will collect and report data during the same time periods?
Answer: Yes. Under the modification, ground ambulance organizations that are selected for year 1 will not collect data in 2020. These ground ambulance organizations will select a new data collection period that begins in 2021 and must submit a completed Medicare Ground Ambulance Data Collection Instrument during the data reporting period that corresponds to their selected data collection period. As a result of the modification, year 1 and year 2 selected ground ambulance organizations will collect and report data during the same time periods. New: 6/16/20
May 22 at 2:20 PM | EMS1 | By AAA Communications Chair Rob Lawrence
In my last EMS One-stop column, I commented on the legislative to-do list to ensure that EMS receives the federal support it deserves right now as we staff the front lines and perhaps brace ourselves for COVID-19 round two as the nation craves a return to the normality and liberty enjoyed before the lockdown.
On May 15, 2020, the much talked about HEROES Act narrowly passed from the U.S. House of Representatives by a 208 to 199 vote to the Republican-controlled Senate. The HEROES Act proposed $3 trillion in tax cuts and spending to address the negative health and financial impacts of the COVID-19 pandemic. This included benefits for the public safety community, extensions to enhanced unemployment benefits, debt collection relief, direct cash payments to households and possibly even hazard pay.
CMS has issued a blanket waiver modifying the data collection period for the ground ambulance services that were selected to report in Year 1. Under the current law, these organizations would have been required to collect data beginning January 1, 2020, and through December 31, 2020. The waiver allows these organizations to select a new continuous 12-month data collection period that begins between January 1, 2021 and ends December 31, 2021. This modification means that such organizations will collect and report data during the same time period as the ground organizations that CMS will select for Year 2 of the cost collection program.
From the summary of the waiver, it appears that organizations will have the choice of submitting data in Year 1 or Year 2. CMS has not moved the timeline for any other data collection year, so there is the potential for a substantial number of organizations to report in Year 2, which would increase the amount of data available.
The AAA has supported the data collection system to make sure that CMS and the Congress have valid and reliable data to support maintaining the geographic add-ons to the Medicare Ambulance Fee Schedule and to support efforts to address the chronic underfunding of the Medicare Ambulance Fee Schedule.
The complete FAQ is below and also available at: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf (on page 29).
“CMS is modifying the data collection period and data reporting period, as defined at 42 CFR § 414.626(a), for ground ambulance organizations (as defined at 42 CFR § 414.605) that were selected by CMS under 42 CFR § 414.626(c) to collect data beginning between January 1, 2020 and December 31, 2020 (year 1) for purposes of complying with the data reporting requirements described at 42 CFR § 414.626. Under this modification, these ground ambulance organizations can select a new continuous 12-month data collection period that begins between January 1, 2021 and December 31, 2021, collect data necessary to complete the Medicare Ground Ambulance Data Collection Instrument during their selected data collection period, and submit a completed Medicare Ground Ambulance Data Collection Instrument during the data reporting period that corresponds to their selected data collection period. CMS is modifying this data collection and reporting period to increase flexibilities for ground ambulance organizations that would otherwise be required to collect data in 2020- 2021 so that they can focus on their operations and patient care.”
“As a result of this modification, ground ambulance organizations selected for year 1 data collection and reporting will collect and report data during the same period of time that will apply to ground ambulance organizations selected by CMS under 42 CFR § 414.626(c) to collect data beginning between January 1, 2021 and December 31, 2021 (year 2) for purposes of complying with the data reporting requirements described at 42 CFR § 414.626.”
It’s finally here! For almost a decade the American Ambulance Association has been preparing for this moment: collecting cost data in order to justify the reimbursement inadequacies of our current payment system. As Benjamin Franklin stated, “By failing to prepare, you are preparing to fail.” So prepare we did!
Our research indicated that due to industry capacity, a provider sample and survey approach would be preferable to a mandatory cost reporting structure. Congress agreed! Our research indicated that different organizational structures made us unique healthcare providers and as such, EMS’s special nature should be considered in the collection tool developed. Congress agreed! No one knows our industry better than we do and the final rule from the Centers for Medicare and Medicaid Services indicates they listened!
So your ambulance service was selected for the 2020 reporting period—now what? Here is your 10 STEP PLAN.
STEP 1: Sign up for the latest information on ambulance cost data collection.
Subscribe to email updates from the American Ambulance Association’s Ambulance Cost Education page, www.ambulancereports.org. Not only will we make sure you get the latest information disclosed from the Centers for Medicare & Medicaid Services, but we will also provide you with quick tutorials on how to fill out the cost data collection instrument. Most importantly, you can purchase AMBER! This software provides an easy, quick solution for you to input your data, with built-in tutorials to walk you through the data collection process.
STEP 2: Know what is included in your National Provider Identification (NPI) number.
It is important that you review the information in the Provider Enrollment, Chain, and Ownership System (PECOS) which supports the Medicare Provider and Supplier enrollment process. You will want to make sure the information that you provide in the cost data collection tool, at a minimum, matches what is in this system or on your CMS 855B Medicare enrollment application. Pay close attention to the following:
- Practice location(s)
- Vehicle Information
STEP 3: “Tele” a Friend!
More than 2,600 ambulance suppliers and providers were selected for the 2020 reporting period (Zip file download of services selected for 2020). Please reach out to your colleagues. Now is not the time to let competition or friendly rivalries stop us from communicating best practices. Call your fellow mobile healthcare providers!
STEP 4: Know your accounting “status.”
How you recognize cost and revenue will be extremely important in determining how you report. Cash accounting recognizes revenue and expenses only when money actually exchanges hands. Accrual accounting recognizes revenue and expenses when billed, not when money exchanges hands. This status will be key in determining how you report costs and revenues.
STEP 5: Know your mileage.
For every ambulance and non-ambulance vehicle that you use related to patient care, you will need to know the odometer readings at the beginning and end of 2020. Make sure you have a system to record the odometer readings accurately.
For example, you have a 2016 ambulance where the odometer reading on 1/1/2020 is 10,212. If on 12/31/2020 the odometer reading is 74,112, you will have the option of recording the full mileage of 63,900 in the data collection tool. This is another window into the “cost of readiness.”
STEP 6: Set up and Identify payer categories.
As identified by the Medicare Ground Ambulance Data Collection System (PDF download), there are nine payer type categories for billing ambulance transportation. Know these categories and set them up in your system now, prior to billing for ambulance transports in 2020. If you use a billing agency, seek confirmation that they have a way to identify these nine payer types. You may not have select reports to identify the numbers yet within these categories but that can be set up later in the reporting year.
Setting up your system NOW to identify these payer categories is critical as it will be too administratively burdensome to fix this retroactively.
STEP 7: Know if you share support services or stand alone.
Support services are services such as maintenance, dispatch, billing, materials management, human resources and other services that support patient care. You will need to know if you share these services with other entities such as fire, police, air ambulance, hospital or other entity not related to ground ambulance care.
If you share, then you will have to work out an allocation model to assign the costs and revenue appropriately. If you do not share support services, then you do not need to work about any of the questions related to allocation.
STEP 8: Identify sources of revenue and cost categories.
Check your systems. Now is the time to make sure you can identify all sources of revenue you receive whether from billing for an ambulance transport or from a grant or local tax. Understand your costs, especially those related to salary, vehicles, facilities and medical supplies. That is the first step in the ability to categorize appropriately.
STEP 9: Don’t panic!
Take a deep breath—It is not as complicated as it may seem. There are resources available and assistance for you and your ambulance services as outlined in STEP 1.
STEP 10: Repeat Step 1!
See, that wasn’t too bad, was it? Now you have a 10 Step Plan!
In all seriousness, while it may seem a bit daunting at first, breaking down the cost data collection process into small steps will ensure that our industry is prepared and the figures we enter into this cost data collection tool will glean useful information. It is imperative that we get this right the first time to avoid any unintended consequences, such as decreased reimbursements and other impactful changes that could harm the patients we serve.
As the saying goes, “the rising tide lifts all boats.” More than ever, we need to help and assist our colleagues as we navigate this new world of ambulance reimbursement.
So, what’s next? Cost data collection, my friend! Jump on board.