Tag: cost data collection

Collecting Data for the Future

Written by Kathy Lester on February 16, 2018. Posted in Cost Survey, Reimbursement.

Collecting Data for the Future: Understanding the New Statutory Cost Collection Requirement

By Kathy Lester, JD, MPH, Lester Health Law PLLC

On February 9, the President signed into law the Bipartisan Budget Act of 2018 which thankfully included a five-year extension of the ambulance add-ons. Along with the add-ons extension, the Congress included language requiring the Centers for Medicare and Medicaid Services (CMS) to develop and implement a new cost data collection system for ambulance service providers and suppliers. While cost collection may sound difficult, the process outlined in the new authority strikes the appropriate balance and will minimize the burden on ambulance service providers and suppliers, while allowing the federal government to collect meaningful data that can be used to address the inadequate reimbursement rates and modernize Medicare ambulance payment policies.

Knowing some time ago that the industry would need to provide CMS with cost information, the AAA for the past six years has been working with The Moran Company, a well-respected health care analytical firm in DC, on the best way to collect ambulance cost data. Most recently, the AAA Payment Reform Committee has been working with the cost collection experts at The Moran Company to identify the data elements that CMS would need to collect to establish accurate information about the cost of providing ground ambulance services. We have also developed educational materials that we will share with Members to help ensure a smooth transition into this system.

General

The core components of the new cost collection system for providers and suppliers of ground ambulance services are:

A requirement that the Secretary of Health and Human Services, through notice-and-comment rulemaking, must develop a data collection system to collect: (1) cost; (2) revenue; (3) utilization; and (4) other information determined appropriate by the Secretary;
This system may use a cost survey; and
The data collect should 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.

Representative Sample

Under the statute, the Secretary must select a representative sample of providers and suppliers from whom to collect data. The sample will be determined based on the type of providers and suppliers (such as those that are part of a governmental organization, fire, hospital-based, etc) and the geographic locations (such as urban, rural, and low-population density areas). An individual provider or supplier (defined most likely by National Provider Identifier) may not be requested to submit data in two consecutive years, to the extent practicable.

Reporting Requirements

A provider or supplier selected to report data must do so in the form and manner and at the time specified by the Secretary. If a provider or supplier that has been selected to report does not do so, then the provider or supplier may be subject to a 10 percent payment reduction, unless the hardship exemption applies. Providers or suppliers that are penalized may seek a review of the application of the penalty. The Secretary does have the authority to take into consideration certain hardships as to why a provider or supplier was unable to submit their data and waive the penalty.

Modification Over Time

The Secretary may revise the system over time.

Public Availability of the Data

The Secretary will provide the information collected available through the CMS Website, similar to the process used for other data CMS collects.

MedPAC Report

In addition, the language includes a study/studies from the Medicare Payment Advisory Commission (MedPAC). MedPAC is required to issue at least one report, and potential subsequent reports, on the following:

An analysis of the information submitted by providers and suppliers through the data collection system;
An analysis of any burden on providers and suppliers associated with the data collection system;
A recommendation as to whether information should continue to be submitted through such data collection system or if it should be revised;
The adequacy of payments for ground ambulance services;
Geographic variations in the cost of furnishing ground ambulance services; and
Other information determined appropriate by the Commission.

Timeline

The Secretary must implement the data collection system according to the following timeline:

The AAA will continue to keep you informed as the development and implementation of the ambulance cost data collection system moves forward.

12/31/2019	Specify the data collection system Identify providers and suppliers that would be required to submit information for the representative sample
2020 – 2024	Collect data each year from a representative sample of providers and suppliers
2022	First year a provider or supplier that has been asked to submit data and has not sufficiently submitted the data may be subject to a 10 percent payment reduction.
2023	MedPAC report due
2025+	Collect data as the Secretary determines appropriate but no less often than once every 3 years

The AAA will continue to work with The Moran Company and other experts to make sure data collection system works for all ambulance service providers and suppliers and leads to information that the industry needs to move toward making the add-ons permanent and modernizing the benefit to include new payment models, including transports to alternative destinations, treatment with referral and no transport, and mobile integrated health.

CMS Releases Ambulance Cost Data Collection Report

Written by Tristan North on December 4, 2015. Posted in Cost Survey, Government Affairs, Medicare, Member Advisories, Member-Only, News, Reimbursement.

The Centers for Medicare and Medicaid Services (CMS) has released its report on the feasibility of collecting cost data from ambulance service providers. Under the American Taxpayer Relief Act of 2012, Congress directed CMS to conduct the report entitled “Evaluation of Hospitals’ Ambulance Data on Medicare Cost Reports and Feasibility of Obtaining Cost Data from All Ambulance Providers and Suppliers”. The report can be accessed here.

The report states that due to the diverse nature of our industry with a majority of providers being small entities, traditional mandatory ambulance cost reporting is not feasible. While it does not make a recommendation on a data collection system, the report highlights the work of the AAA with The Moran Company and will be helpful in our push for a survey approach to collecting ambulance cost data. Here is AAA’ summary of the report, AAA Summary of CMS Acumen Cost Analysis.

The survey approach to collecting ambulance cost data is a major component of the Medicare Ambulance Access, Fraud Prevention and Reform Act (S. 377, H.R. 745) which would make the current Medicare ambulance increases permanent. The data collected through the survey would help the AAA make data-driven recommendations to the Congress and CMS on future changes to the Medicare ambulance fee schedule.

The contractor, Acumen, who developed the report, was also asked to look to see if cost data submitted by hospital-based ambulance service providers would be helpful. Acumen determined that the data submitted varied significantly and thus was not useful.

For questions about the AAA efforts on cost data collection, please contact AAA Senior Vice President of Government Affairs Tristan North at tnorth@ambulance.org.

The Importance of Ambulance Cost Survey Data

Written by Kathy Lester on November 9, 2015. Posted in Cost Survey, Government Affairs, Legislative, Member Advisories, Member-Only, Regulatory, Reimbursement.

By Kathy Lester, JD, MPH | Updated November 9, 2015

Tomorrow is in your hands today. This statement is especially true when we think about the evolution of ambulance services. Today, care once reserved for the hospital setting is now delivered at the scene, resulting in better patient outcomes. Yet, despite these advances, the Medicare payment system lags behind. Current rates are based upon a negotiated rulemaking process that did not take the cost of providing services into accounts. While many in the industry strive to further expand the delivery of high-quality care, the inflexibility of the current payment system makes it difficult to compensate the next generation of ambulance service providers appropriately.

To prepare for tomorrow, ambulances services must act today. The AAA has taken a leadership role by setting the groundwork needed to reform the payment system so that it recognizes the continued evolution of ambulance services. The two game changers are (1) designating ambulance suppliers as “providers” of care; and (2) implementing a federal data collection system.

“Emergency care has made important advances in recent decades: emergency 9-1-1 service now links virtually all ill and injured Americans to immediate medical response; organized trauma systems transport patients to advanced, lifesaving care within minutes; and advances in resuscitation and lifesaving procedures yield outcomes unheard of just two decades ago.”
–Institute of Medicine: Emergency Medical Services at a Crossroads (2007)

Provider Status

Being deemed a “provider” rather than a “supplier” is the first step toward recognizing the clinical component of ambulance services and appropriately incorporating ambulance services into the broader health care coordination and reform discussions.

Under current law, the term provider refers to hospitals, skilled nursing facilities (SNFs), outpatient rehabilitation facilities, home health agencies, ambulatory surgical centers, end-stage renal disease facilities, organ procurement organizations, and clinical labs. Durable medical equipment entities and ambulance services are designated as suppliers.

When ambulance services were first added to the Medicare benefit, the primary services provided were transportation. As noted already, transportation is only one component of the services provided. The deliver of health care services today make ambulances more like other Medicare providers than suppliers.

Achieving this designation is the first step toward having the federal government recognizing the value of the health care services provided by ambulances.

Cost Collection

The second game changer involves collecting cost data from all types and sizes of ambulances services in all areas of the country. Current Medicare rates are not based on cost. As the Government Accountability Office has recognized in two separate reports, these rates do not cover the cost of providing services to beneficiaries. While the Congress has extended the ambulance add-ons year after year, the lack of a permanent fix makes it difficult to plan. There is also the risk of the add-ons not being extended at some point. In addition, the rates take into account only at the most general level the health care being provided.

In the American Taxpayer Relief Act (ATRA), the Congress required the Centers for Medicare and Medicaid Services (CMS) to issue a report evaluating the ability to use current hospital cost reports to determine rates and also to assess the feasibility of obtaining cost data on a periodic basis from all types of ambulance services. Knowing of the strong Congressional interest in obtaining additional cost information, the AAA began working with The Moran Company (a consultant organization with expertise in Medicare cost reporting) to develop recommendations as to how cost data could be most efficiently and effectively collected. The AAA shared these recommendations with CMS and the contractor developing the report. The final report, released in October, supports the AAA’s work and states:

Any cost reporting tool must take into account the wide variety of characteristics of ambulance providers and suppliers. Efforts to obtain cost data from providers and suppliers must also standardize cost measures and ensure that smaller, rural, and super-rural providers and suppliers are represented.

The next step in the process is to provide CMS with direction and authority to implement the AAA’s cost survey methodology. In brief, the methodology would:

Require all ambulance services to report to CMS demographic information, such as organizational type (governmental agency, public safety, private, all volunteer, etc), average duration of transports, number of emergency and nonemergency transports. CMS would use this data to establish organization categories so that the data collected aligns with the type of organization providing it.
Require all ambulance services to report cost data, such as labor costs, administrative costs, local jurisdiction costs, through a survey process. During any survey period, CMS would identify a statistically valid sample of ambulance services in each category to be surveyed. These services would have to provide the data or be subject to a five percent penalty. Those ambulance services that provide data will not be asked to do so again until every service in its organization category has submitted the data.

As part of this process, the AAA has begun developing a common language for reporting these data. This work will ensure that the information is collected in a standardized manner. The AAA will also provide assistance to services that may need extra help in completing the surveys.

This information can then be aggregated and used to evaluate the adequacy of Medicare payments and support additional coverage policies. Most importantly, it will allow policy-makers, the AAA, and other stakeholders to reform the current Medicare ambulance payment system so that it incorporates the health care services currently being provided and those that will be in the future.

Conclusion

In order to be prepared for the reimbursement structures of tomorrow, ambulance services need to be designated a providers and recognized for the health care they provide. They also need to participate in a standardized cost collection program that will provide accurate data in the least burdensome way possible. The AAA is leading the effort to help ambulance services prepare for tomorrow.