Tag: cost data collection

CMS Modifies the Cost Data Collection System Year 1 Data Collection

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.”

40 Under 40: Adam Parker (Sanford Health – Bismarck, ND)

40 Under 40 nominees were selected based on their contributions to the American Ambulance Association, their employer, state ambulance association, other professional associations, and/or the EMS profession.
____

Adam Parker
Operations Manager
Sanford Health
Bismarck, ND

____

Linked In
Nominated By: Kelly Dollinger (North Dakota EMS Association – Bismarck, ND)

____

Biography:

Adam Parker has been involved in North Dakota EMS for over 15 years working for volunteer, private, and hospital-based EMS services. Adam is currently employed by Sanford Health as an Operations Manager overseeing AirMed operations, EMS education and outreach, and a Community Paramedic program. Adam is also a Board Member for the North Dakota EMS Association and serves as Chairman of the Advocacy Committee and Co-chair of the Service Leaders Committee. Adam lives in Bismarck, ND with his wife, Jessica, and two children.

____

Reason for Nomination:

As President of the North Dakota EMS Association – I am thrilled to have the opportunity to nominate Adam Parker for consideration in the AAA’s Inaugural Mobile Healthcare 40 Under 40 – due in part to his exceptional and continued rise through the leadership of North Dakota EMS.

Adam’s full-time position is with Sanford Health as the Operations Manager for the Bismarck and Dickinson AirMed bases, as well as the Sanford EMS Department. In his position, Adam oversees the daily and strategic operations for two air medical bases, as well as EMS outreach and education. Adam also spearheaded the creation of the newly developed Community Paramedic program. Currently, Adam supervises over 50 mobile health care professionals including Paramedics, Community Paramedics, Critical Care Paramedics, and Advanced Certified Registered Nurses.

Adam has successfully obtained his Master’s Degree in Business Administration and also completed the Certified Medical Transport Executive course. Adam is always learning and applying what he learns to better himself and the EMS industry.

On top of his busy schedule, Adam serves on the North Dakota EMS Association Board of Directors. Adam serves as the Co-chair of the Service Leader Committee and is currently the Chairperson for the Advocacy Committee. It is in this capacity where Adam has contributed greatly to our EMS Association and the agencies throughout North Dakota. Adam has been instrumental in obtaining Legislative Grant Funding for North Dakota EMS agencies and assisted in developing a formula to determine funding that would allow for as many ambulance services as possible throughout the state. This proved highly contentious, and risked the loss of all state grant funding, but Adam developed a successful strategy and managed the situation extremely well by negotiating with legislators to find a workable agreement. Adam also serves as our State Advocacy Coordinator and Affiliate Advisory Council representative for the NAEMT.

Adam was also instrumental in advancing the Recognition of EMS Personnel Licensure Interstate CompAct (REPLICA) legislation. This bill successfully passed and North Dakota became the 17th State to be recognized as a REPLICA state.

Adam is very knowledgeable in various aspects of state and local politics, policies, and procedures. Adam is the go-to expert on establishing local taxing districts and he advocates heavily for every ambulance service to establish themselves as a political subdivision, since this is the best way to ensure sustainability in rural areas. Adam freely donates time to meet with and assist ambulance services going through this process as it is very complex and daunting for most rural agencies.

Most recently, Adam has taken it upon himself to educate himself on the inner workings of the Medicare cost data collection process and has contacted every ambulance service selected in the state to ensure they understand what they need to do and has helped them organize themselves to collect the necessary information. Despite Adam’s employer not being selected to submit cost data this year, Adam still gives a lot of his time to ensure that rural ambulance services in North Dakota are successful with this important requirement.

Adam is very generous with this time and freely gives out his phone number and encourages anyone to call if they need help – with anything. There is no doubt that Adam would be of the finest selections for the Inaugural Mobile Healthcare 40 Under 40 in recognition of his contributions to the entire state of North Dakota and the mobile healthcare profession.

____

View all of the 2020 Mobile Healthcare 40 Under 40 Honorees

Savvik Cost Collection Grant Application

The Savvik Foundation and the American Ambulance Association are working together to support ambulance services that are preparing to comply with the Cost Data Collection program through the Centers for Medicare and Medicaid Services. Through Savvik Member purchases under contracts, the Savvik Foundation was able to fund FREE access to Amber, the cost collection software. Services will be eligible to receive a one-year AAA membership, which includes access to experts on cost collection, access to AMBER software, and free registration to Webinars and Regional Workshops. To request your FREE access to Amber, complete the application form here.

Or follow this link: https://ambulancereports.org/request-amber-access/

Cost Data Collection: So You’ve Been Selected—Now What?

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:

  1. Practice location(s)
  2. Vehicle Information
  3. Ownership

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.

Summary of Final Rule on Ambulance Data Cost Collection

Summary of Final Rule on Ambulance Data Cost Collection

The American Ambulance Association (AAA) has completed its review and summary of the Final Rule on the Establishment of an Ambulance Data Collection System drafted by Kathy Lester, Esq. To access the summary of the Final Rule, please click here.

The Final Rule is scheduled to be published in the November 15 issue of the Federal Register.
The AAA will continue to keep you informed about the implementation of the Ambulance Data
Collection System.

Final Rule Summary

CMS Posts Final Ambulance Data Collection Instrument

CMS Posts Final Ambulance Data Collection Instrument

The Centers for Medicare & Medicaid Services (CMS) has posted the final version of the Medicare Ground Ambulance Data Collection Instrument. The Instrument is the guidance and mechanism by which CMS will request data from those ambulance service suppliers and providers selected in year one of the sampling.

The posting of the final version of the Instrument follows the release on November 1 of the final rule on the development of an ambulance data collection system and subsequent release on November 2 of the list of the ambulance service suppliers and providers selected in year one to provide their data. To access the list by NPI number click here and to access the list by state click here.

The AAA will keep you posted of new developments with the implementation of the data collection system as well as educational opportunities.

Provider List by NPI

Provider List by State

CMS Releases List of Ambulance Organizations Selected for Data Collection

CMS Releases List of Ambulance Organizations Selected for Data Collection

The Centers for Medicare & Medicaid Services (CMS) has released the list of ambulance service providers and suppliers selected to provide data in the first year of data collection. CMS has published the data by National Provider Identifier (NPI) number and the AAA has also sorted the data by state in alphabetical order.

On Friday, CMS had made public the final rule on the Establishment of an Ambulance Data Collection System. The AAA will be issuing a Member Advisory tomorrow on the details of the final rule and changes from the proposed rule.

To access the list by NPI number click here and to access the list by state click here.

Provider List by NPI

Provider List by State

CMS Releases Final Rule on Ambulance Data Collection System

Late this afternoon, the Centers for Medicare & Medicaid Services (CMS) released the final rule on the “Establishment of an Ambulance Data Collection System”. The rule was issued as part of the “Medicare Program; CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies” [CMS-1715-F and IFC]. The final rule is scheduled for official publication in the November 15 issue of the Federal Register.

The AAA is currently reviewing the final rule to determine changes on the ambulance data collection system from the policies as outlined in the proposed rule of August 15. The proposed rule set forth a system utilizing a survey tool and sampling of ambulance service providers and suppliers as directed by Congress and supported by the AAA. The AAA did, however, submit comments with suggestions as how to fine-tune the process and tool. The AAA also submitted a second letter on the section of the proposal rule making changes related to the physician certification statement (PCS).

We will be issuing a follow up Member Advisory next week with the specific final policy changes on the ambulance data collection system and PCS outlined in the final rule.

CMS Open Door Forum & Member Q&A – November 7th

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Thursday, November 7 from 2:00-3:30 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call.

CMS Ambulance Open Door Forum

November 7 | 2:00 PM ET
Participant Dial-In Number:  1-888-455-1397
Conference ID #: 4676500

Questions?

Have more questions? The AAA is here to help! Following the ODF the AAA will be publishing a follow up blog post going over any updates and important announcements.

AAA Follow Up Q&A

November 7 | 4:00 PM ET
1-800-250-2600
Pin: 82802314#
Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.

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 Open Door Forum & Member Q&A – August 28

The Centers for Medicare and Medicaid Services has scheduled its next Ambulance Open Door Forum for Wednesday, August 28 at 2:00 PM Eastern. If you plan to attend, please dial in at least 15 minutes before the call.

CMS Ambulance Open Door Forum

August 28 | 2:00 PM ET
Participant Dial-In Number:  1-888-455-1397
Conference ID #: 6609831

Questions?

Have more questions? The AAA is here to help! Following the ODF the AAA will be publishing a follow up blog post going over any updates and important announcements.

AAA Follow Up Q&A

August 28 | 3:00 PM ET
1-800-250-2600
Pin: 82802314#
Speakers: AAA Senior Vice President of Government Affairs, Tristan North; AAA Healthcare Lobbyist, Kathy Lester, Esq.; AAA Medicare Regulatory Committee Chair, Krista Cuthbert; and AAA Payment Reform Committee Chair, Asbel Montes.

CMS Releases Proposed Cost Collection Rule

Today, CMS has released the proposed rule that would establish the ambulance fee schedule cost collection system as required by statute. The AAA is currently reviewing the rule and will provide a more detailed summary in the coming days.

On Tueusday, July 30 at 12:00pm Eastern, the AAA will be hosting a free webinar during which AAA counsel will provide an overview of the proposals in the rule. Do not miss out on this chance for the most up to date information.

Read the Proposed Rule

Sign Up for the Webinar

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

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

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

Thank you for your continued membership and support.

RFP: Cost Collection SME/Project Director

Request for Proposals: Subject Matter Expert (SME)/ Project Director

Ambulance Cost Data Collection
Due April 20, 2019

Overview

The American Ambulance Association (AAA) invites proposals from qualified interested parties (individual and teams) for the purpose of directing the Ambulance Cost Data Project as a Subject Matter Expert (SME).

Introduction

As part of the extension of the Ambulance Medicare Add on payments, legislation passed on February 9, 2018, the Congress mandated that ambulance services provide cost data. General requirements of the legislation include the following:

  • Requires notice-and-comment rulemaking
  • May use a cost survey
  • Collect (1) cost; (2) revenue; (3) utilization; and (4) other information determined appropriate by the Secretary
  • Include information: (1) needed to evaluate the extent to which costs are related to payment rates; (2) on the utilization of capital equipment and ambulance capacity; and (3) on different types of ground ambulance services furnished in different geographic locations and low population density areas
  • May revise the system over time
  • Select a representative sample of providers and suppliers from whom to collect data
  • Determined based on the type of providers and suppliers and the geographic locations
  • May not be request same provider or supplier to submit data in two consecutive years
  • Those selected to report must do so in the form and manner and at the time specified by the Secretary
  • If selected and do not report, then may be subject to a 10 percent payment reduction, unless the hardship exemption
  • Opportunity to request a review of the application of the penalty
  • Information collected available through the CMS Website

AAA Cost Data Collection Objectives

The purpose of the AAA Cost Data Collection is to develop education and service lines to assist the industry in preparing to accurately respond to the federally mandated cost data collection system as designed by the Centers for Medicare and Medicaid Services (CMS). Objectives to include:

  1. Standardization of the education of the cost data collection system including standardization of terms.
  2. The development of a cost data app to be universally distributed and used by ambulance services to report costs.
  3. AAA’s cost data recommendations are considered the industry standard and tools are widely distributed and used by the majority stakeholders of the industry.
  4. Initial (beta) data used to analyze and validate cost collection system, and provide data needed to continue lobbying Congress on additional reimbursement payments.

Proposed Project Director (SME) Scope of Work

In order to achieve the above objectives, the following is the proposed director (SME) scope of work:

  • Review and comment on AAA Cost Data Collection deliverables, including publications, education efforts, and online tools, helping to maximize accessibility and utility while verifying accuracy.
  • In partnership with the Technology and Education contractor, provide industry and ambulance service support, both reactively in answering questions and proactively in presentations both remotely and in person.
  • In collaboration with the AAA Cost Data Collection Faculty, contribute and edit content for the data collection operational definitions.
  • Update website, write articles, member communications and information pieces for distribution and website posting.
  • Working with the Technology and Education contractor, monitor and support the receipt of initial data, reviewing to identify missing fields and outliers; follow-up and clean data as needed.
  • Using data generated by the data collection system, generate articles and reports reflecting analysis and synthesis.
  • As requested, prepare reports and provide counsel to the AAA Board throughout the term of the project.

Proposed Timeline of Work

  • May 1, 2019 Hire SME
  • May–June 2019 Review and finalization of operational definitions
  • Summer 2019 Review of Amber online toolset, support of pilot testing
  • September-December Ongoing education – including train the trainer materials and final pre-launch education
  • Throughout 2019-2020 Ongoing educational and awareness-raising work, development and enhancement of website content

Instructions for Submission of Responses

Please include the following information in your Response.

  • Cover letter indicating cost for providing services as outlines in the RFP.
  • Resume and/or Curriculum Vitae (CV)
  • A list of three references (including phone numbers), as well as a brief description of the project for the reference
  • Any samples you wish to use to showcase your work as a project director and/or SME

Submit the above materials to Maria Bianchi electronically to mbianchi@ambulance.org.

Deadline

We would appreciate a response to the proposal no later than April 20, 2019. If you have any questions, contact Maria Bianchi at 301-758-2927.

Summary of March 28, 2019 Ambulance ODF

The Centers for Medicare and Medicaid Services (CMS) held its latest Open Door Forum on Wednesday, March 28, 2019.  As with past Open Door Forums, CMS started the call with the following announcements:

  1. Ambulance Cost Data Collection – CMS reminded the industry that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, requires CMS to create a new cost data collection system by December 31, 2019.
  2. Emergency Triage, Treat, and Transport Model – A representative from the Innovation Center within CMS provided an overview of the “Emergency Triage, Treat, and Transport Model” or “ET3.” This is a 5-year pilot program intended to provide ambulance providers with greater flexibility to handle low-acuity 911 calls, by providing Medicare payment for: (a) ambulance transportation to alternative treatment destinations and (b) treatment at the scene. The CMS representative indicated that CMS is in possession of data that suggests that 16% of emergency ambulance transports to a hospital emergency department could have been resolved by transporting the patient to an alternative treatment site, e.g., an urgent care center. CMS estimates that had all of these patients elected to receive care in the lower-acuity setting, it would have saved the Medicare Program approximately $560 million each year. With respect to the operation of the model itself, CMS essentially repeated the information that had been previously provided on its webinars. You can view the AAA Member Advisory on the ET3 Model by clicking here.
  3. Ambulance Inflation Factor – CMS reiterated that the 2019 Ambulance Inflation Factor is 2.3%.

Following the announcements, CMS moved into a Question & Answer period. The majority of the questions related to the ET3 pilot program. As is typical, many questions were not answered on the call; instead, CMS asked the individual to submit their question in writing. However, the following questions were answered on the call:

  1. Payment Rates under ET3 – CMS was asked whether the BLS base rate payment would be the BLS emergency base rate. It was not clear that the CMS representative fully understood the question, although she indicated that it would.
  2. Eligibility for Government Agencies – CMS was asked whether governmental agencies that operate 911 centers would submit applications to participate as part of the RFA process in the Summer of 2019. CMS responded that governmental agencies that operate 911 centers would not submit RFAs, but would rather wait for the Notice of Funding Opportunity (NOFO), which will be issued after the ambulance providers and suppliers are selected for participation (expected to be the late Fall/Winter of 2019). CMS further confirmed that if the governmental agency also operated its own ambulance service that it would be eligible to apply for both aspects of the ET3 Model.
  3. Limit on Ambulance Providers – CMS was asked whether it would cap the number of ambulance providers and suppliers selected to participate in the program. CMS responded that, at the present time, it has no intent to cap the number of participating ambulance providers and suppliers at any specific number.
  4. Return Transports from Alternative Treatment Destinations – CMS was asked whether the model would provide for ambulance payment for the return transport after a patient was transported to an alternative treatment site. CMS indicated that the model does not provide for payment for the return transport.
  5. Definition of “Telehealth” – CMS confirmed that the model will use the same definition of “telehealth” used in other areas of the Medicare Program. CMS further confirmed that telehealth encounters require both audio and video connections.
  6. Approval of Alternative Treatment Sites – CMS confirmed that state and local regulatory agencies would have final approval over acceptable alternative treatment sites.
  7. Qualified Health Care Practitioner – CMS confirmed that a “qualified health care practitioner” would be an individually enrolled Medicare practitioner, which includes physicians and nurse practitioners. In some instances, it can also include physician’s assistants. CMS confirmed that the definition would not include registered nurses or advance scope paramedics.
  8. NOFO Funding – CMS indicated that, at the present time, it is not prepared to release additional details on the nature or size of the funding opportunities available to governmental agencies and their designees that operate or have authority over 911 centers.
  9. Medicare Advantage and Other Payers – CMS confirmed that the ET3 Model applies only to Medicare beneficiaries enrolled in FFS Medicare. It does not apply to Medicare Advantage enrollees, Medicaid recipients, etc.

Questions? Email Brian at bwerfel@aol.com

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

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

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

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

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

 

 

Rural Health Day Advocacy Update

Happy National Rural Health Day! Thank you to all of the ambulance service providers who work hard providing life-saving treatment in rural areas every day.

In part of our ongoing advocacy efforts, the AAA sent a letter today to the Rural Caucuses in the United States Senate and House of Representatives. Addressed to leadership of the caucuses, Sen. Pat Roberts (R-KS), Sen. Heidi Heitkamp (D-ND), Rep. Adrian Smith (R-NE), and Rep. Tim Walz (D-MN), this in-depth letter highlights the critical work that our members do every day around the country and raises important issues affecting the industry. Issues covered in the letter include:

Stabilizing the Ambulance Fee Schedule
  • Make the add-ons permanent and build them into the base rate
  • Use new data from the ambulance cost collection program to ensure reimbursement is adequate going forward
  • New data should be used to assess the problems with the current ZIP-code methodology for determining rural and super-rural services
Ambulance Fee Schedule Reform
  • Proposed alternative models for rural ambulance services
  • Encouraging Congress to look at alternative destination options for ambulance service providers
Recognizing Ambulance Services as Providers of Health Care
  • Moving non-fire-based ambulance services from suppliers to providers under Medicare

The letter also highlights some of the burdensome regulations facing ambulance service providers that the AAA has recommended Congress address through its Red Tape initiative. These include:

Removing Unnecessary Regulatory Burdens:
  • Reduce the burdens created by the Physician Certificate Statement
  • Simplify the 855B Ambulance Enrollment Form
  • Address burdensome requirements of the patient signature on claims and the strict application of the revocation of billing authority

This letter from the AAA to Congressional leaders is just one part of the AAA’s ongoing effort to educate Congress on the crucial role ambulance service providers play in America’s healthcare system. The AAA wants Congress to know that in many rural areas of the country, ambulances are the medical safety net, yet face extreme challenges to staying in business thanks to below cost reimbursement and burdensome regulations. The AAA will continue to pursue this list of priorities with our members next year and going forward.

Read the Full Letter

Again, Happy Rural Health Day to our members – thanks for all that you do!

If you have any questions about our letter or rural advocacy, please contact us:

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

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

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

Thank you for your continued membership and support.

Request for Proposals—SME/Project Director

American Ambulance Association
Request for Proposals
SME/ Project Director
Ambulance Cost Data Collection
November 2018

Overview

The American Ambulance Association (AAA) invites proposals from qualified interested parties (individual and teams) for the purpose of directing the Ambulance Cost Data Project as a Subject Matter Expert (SME).

Introduction

As part of the extension of the Ambulance Medicare Add on payments, legislation passed on February 9, 2018, the Congress mandated that ambulance services provide cost data.  General requirements of the legislation include the following:

  • Requires notice-and-comment rulemaking
  • May use a cost survey
  • Collect (1) cost; (2) revenue; (3) utilization; and (4) other information determined appropriate by the Secretary
  • Include information: (1) needed to evaluate the extent to which costs are related to payment rates; (2) on the utilization of capital equipment and ambulance capacity; and (3) on different types of ground ambulance services furnished in different geographic locations and low population density areas
  • May revise the system over time
  • Select a representative sample of providers and suppliers from whom to collect data
  • Determined based on the type of providers and suppliers and the geographic locations
  • May not be request same provider or supplier to submit data in two consecutive years
  • A selected to report must do so in the form and manner and at the time specified by the Secretary
  • If a selected and do not report, then may be subject to a 10 percent payment reduction, unless the hardship exemption
  • Opportunity to request a review of the application of the penalty
  • Information collected available through the CMS Website

AAA Cost Data Collection Objectives

The purpose of the AAA Cost Data Collection is to develop education and service lines to assist the industry in preparing to accurately respond to the federally mandated cost data collection system as designed by the Centers for Medicare and Medicaid Services (CMS). Objectives to include:

  1. Standardization of the education of the cost data collection system including standardization of terms.
  2. The development of a cost data app to be universally distributed and used by ambulance services to report costs.
  3. AAA’s cost data recommendations are considered the industry standard and tools are widely distributed and used by the majority stakeholders of the industry.
  4. Initial (beta) data used to analyze and validate cost collection system, and provide data needed to continue lobbying Congress on additional reimbursement payments.

Proposed Project Director (SME) Scope of Work

In order to achieve the above objectives, the following is the proposed director (SME) scope of work:

  • Review and comment on AAA Cost Data Collection deliverables, including publications, education efforts, and online tools, helping to maximize accessibility and utility while verifying accuracy.
  • In partnership with the Technology and Education contractor, provide industry and ambulance service support, both reactively in answering questions and proactively in presentations both remotely and in person.
  • In collaboration with the AAA Cost Data Collection Faculty, contribute and edit content for the data collection operational definitions.
  • Update website, write articles, member communications and information pieces for distribution and website posting.
  • Working with the Technology and Education contractor, monitor and support the receipt of initial data, reviewing to identify missing fields and outliers; follow-up and clean data as needed.
  • Using data generated by the data collection system, generate articles and reports reflecting analysis and synthesis.
  • As requested, prepare reports and provide counsel to the AAA Board throughout the term of the project.

Proposed Project Timeline

December, 2018 — Board Consideration of AAA Cost Data Collection Proposal and Budget Request

January 1, 2019 — Hire SME

January–February 2019 — Development of operational definitions

March–April 2019 — Review and finalization of operational definitions

Summer 2019 — Review of Amber online toolset, support of pilot testing

September-December — Ongoing education – including train the trainer materials and final pre-launch education

Throughout 2019 — Ongoing educational and awareness-raising work, development and enhancement of website content

Instructions for Submission of Responses

Please include the following information in your Response.

  • Cover letter indicating cost for providing services as outlines in the RFP.
  • Resume and/or Curriculum Vitae (CV)
  • A list of three references (including phone numbers), as well as a brief description of the project for the reference
  • Any samples you wish to use to showcase your work as a project director and/or SME

Submit the above materials to Maria Bianchi electronically at mbianchi@ambulance.org.

We would appreciate a response to the proposal no later than Friday, December 7, 2018.

If you have any questions, contact Maria Bianchi at 301-758-2927.

CMS Launches Outreach Effort to Ambulance Providers & Suppliers

As part of the Bipartisan Budget Act of 2018 (BBA 2018), the Congress instructed CMS to develop a cost collection system to collect cost and revenue data related to the provision of ambulance services. Ambulance services are defined by federal law to include all levels of emergency and non-emergency services. 

CMS is in the first phase of this process. The Congress instructed the Agency to engage with stakeholders before specifying through notice and comment rulemaking the data collection system. By law, CMS is required to specify the final system by December 31, 2019. CMS must also identify the first group of providers and suppliers selected for the first representative sample by that date as well. It appears that the goal is to have the contractor develop a proposal before the 2019 rulemaking cycle which will begin next summer.

To engage with the stakeholders, CMS, through its contractor the RAND Corporation, is reaching out providers and suppliers to learn more about the costs and revenues associated with providing ambulance services.

During the American Ambulance Association’s annual meeting earlier this month, CMS through the RAND Corporation, convened a focus group where they selected several AAA members who were able to talk directly with the contractor. The discussion centered around characteristics of ambulance services that matter for determining costs. The group also talked about how data is currently captured at the state and local levels, as well as how data is tracked within ambulance services. There was also a lot of discussion about the importance of standardizing data elements and not relying upon different state or local definitions, which could confound the data and make it impossible to compare costs across states.

As we have reported previously, it is critically important that the data collected through this process is standardized and reflects the actual cost of providing ambulance services. It is important to make sure that the data is useable not only for supporting the ambulance add-ons after they next expire in 2023, but also to help implement broader reforms and innovative payment models.

CMS is now reaching out to others in the industry. If you receive an email or a phone call from RAND Corporation, please respond. 

If you have questions about, or would like assistance with regard to, this project, please contact Tristan North at tnorth@ambulance.org.

Stay In Touch!

By signing up, you agree to the AAA Privacy Policy & Terms of Use

PO Box 96503 #72319
Washington, DC 20090-6503
hello@ambulance.org

Customer Service

Email hello@ambulance.org to open a support ticket for friendly assistance!

Media Inquiries

media@ambulance.org (Press only, please.)

© 2023 American Ambulance Association, Inc.