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Tag: COVID-19 coronavirus

CMS Increases Medicare Payment for COVID-19 Vaccinations

Written by Brian Werfel on . Posted in Drugs & Pharma, Emergency Preparedness, Medicare, Reimbursement.

CMS Increases Medicare Payment for COVID-19 Vaccinations

 

                                                                        By Brian S. Werfel, Esq.

On March 15, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that it would be increasing the Medicare payment amount for administrations of the COVID-19 vaccines.

The original Medicare reimbursement rate depended, in part, on whether the vaccine being administered required a two-dose regimen (as is the case for the Pfizer-Biontech and Moderna vaccines), or a single dose (Johnson & Johnson vaccine).  For vaccinations that require a two-dose regime, CMS initially paid: (1) $16.04 for the administration of the first dose and (2) $28.39 for the administration of the second dose.  For vaccines that require only a single dose, Medicare paid $28.39 for the administration of that single dose.

Effective for vaccinations administered on or after March 15, 2021, CMS has increased these payments to $40 per administration.  Thus, the total reimbursement for a vaccine requiring a single dose will be $40, while the total reimbursement for a vaccine requiring a two-dose regimen will be $80.

EMS1 | COVID-19 Vaccination Podcast

Written by Rob Lawrence on . Posted in Employee Wellness.

From Rob Lawrence’s EMS One Stop Podcast at EMS1

Scott Moore on COVID-19 Vaccination: EMS One-Stop With Rob Lawrence

The American Ambulance Association HR Consultant discusses options open to EMS managers to ensure providers are vaccinated

The word of the week is vaccine, but is it giving EMS leaders a headache already? Host Rob Lawrence discusses the issues with American Ambulance Association HR Consultant, Scott Moore. Rob and Scott discuss the options open to managers to ensure all are vaccinated, while acknowledging the hope that science and understanding will prevail. They also discuss the other major news item of the week, EMS funding and the lack of it as reduced incomes put the very viability of service delivery at risk.

Scott Moore is a Massachusetts licensed attorney and possesses certifications as both a Professional in Human Resources (PHR) and the Society for Human Resources Management Certified Professional (SHRM-CP). He is a member of the American Bar Association (ABA), the Massachusetts Bar Association (MBA), the Northeast Human Resource Association (NEHRA), and the Society for Human Resource Management (SHRM).

In addition, Scott is an active member of the American Ambulance Association and has been a site reviewer for the Commission for the Accreditation of Ambulance Services (CAAS) for many years.

Read Rob’s article, “The word of the week is vaccine,” and listen to the podcast below.

CDC Advisory Committee Recommends EMS for Phase 1 Vaccine Distribution

Written by Kathy Lester on . Posted in Member Advisories.

As reported in various media outlets, on December 1 the Center for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP) voted 13-1 to recommend that health care providers, expressly including EMS personnel, be prioritized to receive the COVID-19 vaccines during Phase 1a of the vaccine distribution plan. The complicating factor is that State and local governments have the final say in whether these recommendations are incorporated into their own distribution plans. Thus, we encourage all AAA members to engage actively with their State and local governments to urge the adoption of the CDC recommendation. The AAA has developed a toolkit for members to use in reaching out to their state and local government officials.

View and Download Toolkit Here►

The AAA has been engaging with ACIP and other federal policy makers to urge them to prioritize EMS in the vaccine distribution plan. On November 19, the AAA submitted a comment letter to the ACIP advocating that the advisory committee specifically include EMS personnel in their recommendation of groups in the first phase of receiving the vaccination. Even though States and local governments will create their own list, having EMS listed in Phase 1a CDC recommendations is a critically important step toward influencing the State and local process.

During its second emergency meeting in less than a month, ACIP met to develop recommendations on the prioritization of vaccines, given that it will be impossible to provide access to everyone in the United States immediately after the vaccines are approved. In both virtual meetings, Committee members noted the importance of EMS personnel having access to the vaccine in the very top tier for prioritization. Other health care personnel on this list are defined as hospitals, long-term care facilities, outpatient clinics, home health care, pharmacies, and public health. The Phase 1a tier also includes residents of nursing homes, assisted living facilities, and other residential care settings, given that approximately 40 percent of all COVID-19 deaths have occurred in these settings. The final recommendation approved states:

When a COVID-19 vaccine is authorized by FDA and recommended by ACIP, vaccination in the initial phase of the COVID-19 vaccination program (Phase 1a) should be offered to both 1) health care personnel§ and 2) residents of long-term care facilities.

Health care personnel are defined as paid and unpaid persons serving in health care settings who have the potential for direct or indirect exposure to patients or infectious materials.

Long-term care facility residents are defined as adults who reside in facilities that provide a variety of services, including medical and personal care, to persons who are unable to live independently.

The CDC plans to publish this recommendation in the Morbidity Mortality Weekly Report as well.

The only controversial issue related to whether long-term care facility residents should receive the vaccine given the limited information available about its effectiveness and safety in these populations.

Because President Trump has indicated that State and local governments do not have to follow the CDC recommendations, it is critically important that AAA members work closely with their State and local governments to ensure that the CDC recommendations with regard to EMS are adopted by them as well. The AAA has posted a tool kit on our website to help our members provide the necessary information to their State and local governments as they are making these decision.

ACIP will continue to evaluate the distribution prioritization for Phase 1b, which will likely be non-health care essential workers, and Phase 1c, which will include adults with high-risk medical conditions and adults 65 years or older.

CMS: Revised Repayment Terms for Medicare Accelerated Payments

Written by Brian Werfel on . Posted in Operations, Patient Care.

On October 8, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a Fact Sheet setting forth the repayment terms for advances made under the Medicare Accelerated and Advance Payments Program (AAPP).  These changes were mandated by the passage of the Continuing Appropriations Act, 2021 and Other Extensions Act, which was enacted on October 1, 2020.

Background

On March 28, 2020, CMS expanded the existing Accelerated and Advance Payments Program to provide relief to Medicare providers and suppliers that were experiencing cash flow disruptions as a result of the COVID-19 pandemic, and associated economic lockdowns.  Under the AAPP, Medicare providers and suppliers were eligible to receive an advance of up to three months of their historic Medicare payments.  These advances are structured as “loans,” and are required to be repaid through the offset of future Medicare payments.

CMS began accepting applications for Medicare advances in mid-March 2020, before ending the program in late April following the passage of the CARES Act.  CMS ultimately approved more than 45,000 applications for advances totaling approximately $100 billion, before it suspended the program in late April 2020.

Under the pre-existing terms of the AAPP, repayment through offset was required to commence on the 121st day following the provider or supplier’s receipt of the advance funds.  The program also called for a 100% offset until all advanced funds had been repaid.

Revised Payment Terms

Under the revised payment terms announced by CMS, providers and suppliers will not be subject to recoupment of their Medicare payments for a period of one year from the date they received their AAPP payment.  Starting on the date that is one year from their receipt of the AAPP payment, repayment will be made out of the provider’s or supplier’s future Medicare payments.  The schedule for such repayments will be as follows:

  • 25% of the provider’s or supplier’s Medicare payments will be offset against the outstanding AAPP balance for the next eleven (5) months; and
  • 50% of the provider’s or supplier’s Medicare payments will be offset against the outstanding AAPP balance for the next six (6) months

To the extent there remains an outstanding AAPP balance after that 17 month period (i.e., 29 months after the date the provider or supplier received its AAPP payment, the provider or supplier will receive a letter setting forth their remaining balance.  The provider or supplier will have 30 days from the date of that letter to repay the AAPP balance in full.  To the extent the AAPP balance is not repaid in full within that 30-day period, interest will begin to accrue on the unpaid balance at a rate of 4%, starting from the date of the letter.

Medicare providers and suppliers are also permitted to repay their accelerated or advance payments at any time by contacting their Medicare Administrative Contractor.

 

CMS: COVID Testing and Screening Guidance for SNF and Long-Term Care Facilities

Written by Brian Werfel on . Posted in Operations, Patient Care.

On August 25, 2020, the Centers for Medicare and Medicaid Services (CMS) published an interim final rule with a comment period titled “Medicare and Medicaid Programs, Clinical Laboratory Improvement Amendments of 1988 (CLIA), and Patient Protection and Affordable Care Act; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.”  The interim final rule sets forth a number of new requirements designed to limit the COVID-19 exposure and to prevent the spread of COVID-19 within nursing homes.

Specifically, the interim final rule requires skilled nursing and other long-term care facilities to test residents and staff for COVID-19.  The frequency of such testing is based on the positivity rate in which the facility is located, and can require COVID-19 testing as frequently as twice per week.  Regardless of the frequency of required COVID-19 tests, facilities must also screen all staff, residents, and persons entering the facility for the signs and symptoms of COVID-19.

These requirements extend to individuals that provide services to nursing homes under arrangements, including health care personnel rendering care to residents within the facility.  In subsequent guidance, CMS clarified that these testing and screening requirements apply to EMS personnel and other health care providers that render care to residents within the facility.  However, in that same guidance, CMS indicated that EMS personnel must be permitted to enter the facility provided that: (1) they are not subject to a work exclusion as a result of to an exposure to COVID-19 or (2) showing signs or symptoms of COVID-19 after being screened.”  CMS further indicated that “EMS personnel do not need to be screened so they can attend to an emergency without delay.”

In plain terms, CMS has created an affirmative obligation on nursing homes to ensure that any individual that provides services under a contractual arrangement with the nursing home comply with these testing and screening requirements.  CMS has expressly waived the screening requirements for EMS personnel responding to medical emergencies at a nursing home.  However, CMS has not specifically addressed the testing and screening requirements applicable to EMS personnel responding to nursing homes in non-emergency situations. 

The A.A.A. is aware that a handful of State Health Agencies have issued their own guidance on this issue.  The A.A.A. is also aware that individual nursing homes have started to require proof that EMS personnel have been tested for COVID-19 prior to allowing these individuals to enter the nursing home in a non-emergency situation.

EMS agencies may already be subject to state and local testing mandates.  EMS agencies may also have their own internal policies that require employees to be periodically tested for COVID-19.  As a result, there exists the potential for conflict where these existing testing policies conflict with the testing requirements of your local nursing homes.

The A.A.A. has been engaged in an ongoing conversation with CMS on these issues since the issuance of the interim final rule in August.  As part of that conversation, the A.A.A. pushed for the exclusion of EMS personnel from the screening requirement when responding to medical emergencies, which was included in the recent CMS guidance document.  The A.A.A. also continues to push for additional funding for COVID-19 testing for EMS agencies.  CMS has recognized that the frequent testing of health care workers is essential to reducing the spread of the novel coronavirus.  CMS has allocated funding for these purposes to other industries, including hospitals and nursing homes.  As front-line health care workers, EMS agencies should have similar access to testing funds.  The A.A.A. will continue to push for funding equity for the EMS industry.

In the interim, we strongly encourage our members to work with their state associations and other stakeholders to advocate for reasonable rules related to testing on the state and local levels.  To the extent the applicable state or local agency has determined the appropriate frequency for the testing of EMS personnel responding to medical emergencies, those rules should also apply to EMS personnel responding to scheduled transports and other non-emergencies that start or end at a nursing home.  Requiring more frequent testing in these situations would impose an undue burden on EMS agencies that provide these services.  More frequent testing may also prove counterproductive, as it may discourage EMS agencies that cannot meet these higher requirements from responding in these situations.  We also encourage our members to continue to push for state and local funding for the testing of their employees.

 

U.S. House of Representatives Approves Continuing Resolution

Written by Brian Werfel on . Posted in Government Affairs, Legislative.

On September 22, 2020, the U.S. House of Representatives approved a continuing resolution to keep the government funded through December 11, 2020.  Under current law, government funding is set to expire at midnight on September 30, 2020.

The House resolution is a stopgap measure that would maintain funding for most government programs at their current Fiscal Year 2020 levels.  However, the Continuing Resolution omits $30 billion in agricultural aid sought by the Trump Administration and Senate Republicans.  As of last week, it appeared that a compromise had been struck between the Administration and Speaker Pelosi under which the agricultural aid would be tied to the extension of special food benefits to recipients of free or reduced-price school lunches authorized by the Families First Coronavirus Response Act.  The Continuing Resolution also does not include new spending on economic aid for those impacted by the coronavirus.

The Continuing Resolution will now go to the U.S. Senate for consideration.

Impact on Repayment of Medicare Accelerated and Advance Payments

In response to the COVID-19 pandemic, CMS announced that it would be opening the Medicare Accelerated and Advance Payment Program (AAPP) to all health care providers and suppliers that were impacted financially by the pandemic.  Under the AAPP, Medicare-enrolled providers and suppliers were eligible to receive an advance of up to three months of their historic Medicare payments.  These advances were structured as “loans,” and were required to be repaid through the offset of future Medicare payments.  CMS began accepting applications for Medicare advances in mid-March 2020, before ending the program in late April following the passage of the CARES Act.  CMS ultimately approved more than 45,000 applications for advances totaling approximately $100 billion, before it suspended the program in late April 2020.

Under the existing terms of the AAPP, repayment through offset was required to commence on the 121st day following the provider or supplier’s receipt of the advance funds.  The program also called for a 100% offset until all advanced funds had been repaid.

The American Ambulance Association, the American Hospital Association, the Association of American Medical Colleges, and numerous other advocacy groups have advocated that the AAPP be revised to give health care providers and suppliers greater flexibility to repay the advanced funds.  The AAA and others argued that these changes were necessary to avoid a financial crisis when CMS began offsetting Medicare payments to repay the advanced funds.  A copy of the AAA’s letter to CMS Administrator Seema Verma can be viewed by clicking here.

In the Continuing Resolution, the House addressed this issue by making the following changes to the AAPP:

  • Hospitals and Other Part A Providers: Upon request of the hospital or other Part A provider: (1) provide for 1 year before claims are offset to recoup the advanced funds, (2) limit the offset to not more than 25% of the payment on a future claim for the first 11 months during which offsets are required, (3) limit the offset to not more than 50% during the next 6 months, (4) provide for up to 29 months (from the date the advanced payments were first received) before requiring that the outstanding balance be paid-in-full, and (5) limit the interest charged on the unpaid principal balance of any advanced funds to 4%.
  • Part B Suppliers: Upon request of the supplier: (1) provide for 1 year before claims are offset to recoup the advanced funds, (2) limit the offset to not more than 25% of the payment on a future claim for the first 11 months during which offsets are required, (3) limit the offset to not more than 50% during the next 6 months, (4) provide for up to 29 months (from the date the advanced payments were first received) before requiring that the outstanding balance be paid-in-full, and (5) limit the interest charged on the unpaid principal balance of any advanced funds to 4%.

The Continuing Resolution would require the HHS Secretary to post within 2 weeks of enactment (and updated every 2 weeks thereafter) the following information related to the AAPP on the CMS website:

  • The total amount of such payments under each part of the program, including the specific percentage of such payments made out of the Federal Hospital Insurance Trust Fund and the Federal Supplementary Insurance Trust Fund;
  • The total amount of payments under each part of the program, by industry type;
  • The CMS identifier and the amounts received by each health care provider or supplier.

HHS would also be required to post periodic reports, starting in July 2021 and every six months thereafter until all AAPP amounts have been repaid, that contain the following:

  • The total amounts yet to be repaid;
  • The total amounts yet to be repaid, by industry type;
  • The total amounts repaid under each program, including the specific percentage of such repayments deposited back to the Federal Hospital Insurance Trust Fund or the Federal Supplementary Insurance Trust Fund; and
  • The total interest collected on all repayments

The Senate will most likely approve the House CR before the September 30, 2020 deadline.

 

Update – SNF COVID-19 Testing Does Not Apply to EMS

Written by Kathy Lester on . Posted in Operations, Patient Care.

CMS Clarify in Guidance that EMS Personnel Are Not Required To Be Tested under Skilled Nursing Facility Testing Interim Final Rule

The Centers for Medicare & Medicaid Services (CMS) have issued guidance clarifying the types of personnel who are subject to the testing requirements when entering a Skilled Nursing Facility (SNF) in the Interim Final Rule with Comment (IFC) on Additional Policy and Regulatory Revisions in Response to the COVID– 19 Public Health Emergency.  The new guidance memo states:

 

Entry of Health Care Workers and Other Providers of Services

Health care workers who are not employees of the facility but provide direct care to the facility’s residents, such as hospice workers, Emergency Medical Services (EMS) personnel, dialysis technicians, laboratory technicians, radiology technicians, social workers, clergy etc., must be permitted to come into the facility as long as they are not subject to a work exclusion due to an exposure to COVID-19 or show signs or symptoms of COVID-19 after being screened. We note that EMS personnel do not need to be screened so they can attend to an emergency without delay. We remind facilities that all staff, including individuals providing services under arrangement as well as volunteers, should adhere to the core principles of COVID-19 infection prevention and must comply with COVID-19 testing requirements.

 

CMS issued this guidance at the request of the American Ambulance Association (AAA) to address concerns our members had raised about some SNFs misinterpreting the requirements.  The guidance is also consistent with AAA’s interpretation of the IFC.   As we indicated in an earlier Member Advisory, the IFC requires SNFs to test certain individuals for COVID-19 before they enter the facility.  Specifically, it applies to employees, consultants, and contractors of a skilled nursing facility (SNF).  It does not apply to vendors, suppliers, attending physicians, family, or visitors. Providers, such as medical directors and hospice, that are under a contract or consultants to a SNF are subject to the rule.  EMS personnel do not come within the scope of the IFC.

 

Even though the testing requirements of the IFC do not extend to ground ambulance services that do not have a contractual relationship with a SNF, the AAA supports the efforts of all of our members to follow the World Health Organization and Centers for Disease Control and Prevention Guidelines to have EMT and paramedics use full Personal Protective Equipment (PPE) when they are engaging with any patient, not only those in SNFs.  We also want to recognize the best practices of many members who have worked with SNFs to establish outdoor locations where the SNF personnel, when possible, can bring a patient out of the building to transfer the patient to the ambulance.  These and other examples of safe practices can help control the spread of COVID-19, which is the paramount concern.

Expanded Support for EMS Responding to Natural Disasters, COVID-19

Written by Amanda Riordan on . Posted in News, Operations, Press.

Frontline Impact Project Expands Support for Frontline Heroes, Offers Companies a New Way to Give Amidst Historic Natural Disasters

COVID-19 response platform will now direct resources to first responders facing wildfires, hurricanes and other catastrophes   

September 15, 2020 – Frontline Impact Project is expanding its mission and will now also support heroes on the frontlines of major natural disasters including the Western wildfires and Hurricane Laura. The platform, which The KIND Foundation launched in partnership with dozens of companies in response to COVID-19, will activate its existing infrastructure to shepherd resources like meals, snacks, beverages and personal care items to first responders in need. The announcement comes after extraordinary displays of courage and sacrifice from the nation’s firefighters, paramedics and emergency volunteers.

“We started Frontline Impact Project to meet the needs of those on the frontlines of the COVID-19 pandemic. While this work will continue, we are cognizant of the many others risking their lives to keep us safe, particularly as peak wildfire and hurricane seasons approach,” says Michael Johnston, President of The KIND Foundation. “Thanks to the generosity of more than 60 companies, we’re set up to respond in real time and help take care of America’s heroes as they take care of us.”

As part of this expansion, Frontline Impact Project has initiated partnerships with two leading disaster response nonprofits, National Voluntary Organizations Active in Disaster (NVOAD) and Good360, to get donated items to workers across the Gulf Coast and Western United States.

“Non-profit staff and volunteers work tirelessly to serve survivors impacted by disaster. Frontline Impact Project’s commitment and efforts to supporting those serving on the frontlines of disasters across the country is a welcome addition to the disaster response community,” says Katherine Boatwright, Director of Operations, NVOAD.

Since April, Frontline Impact Project has matched more than 650 frontline institutions with companies that have products or services to donate. Available resources include food, beverages, personal care items, mental health services and virtual fitness classes. Together with its inaugural partner KIND, the project has donated nearly four million products to date.

“We were looking for a flexible and streamlined way to donate our products. Frontline Impact Project gives us the opportunity to scale our giving as the situation demands and reach a deserving audience whose needs are paramount but not always top of mind,” says Aaron Croutch, Executive Vice President, Lenny & Larry’s.

Kara Goldin, Founder and CEO of Hint, adds, “Now, more than ever, it’s critical that we support first responders and help keep them healthy and hydrated. Hint has donated water to hundreds of healthcare organizations and first responders across the country, and the Frontline Impact Project has made coordination with a number of those groups much easier.”

In addition to Lenny and Larry’s and Hint, a number of companies have signed on to support this effort, including Adrenaline Shoc Smart Energy; Belgian Boys; CLEAN Cause; Just the Cheese; Kabaki Tea; Kodiak Cakes; KIND; La Colombe; Neuro; Paunchy Elephant; RISE Brewing Co; ROWDY; Purely Elizabeth; and ZICO Coconut Water.

To submit a donation or make a request, visit www.frontlineimpact.org.

Preliminary Calculation of 2020 Ambulance Inflation Update

Written by Brian Werfel on . Posted in Finance, Government Affairs, Medicare, Reimbursement.

Section 1834(l)(3)(B) of the Social Security Act mandates that the Medicare Ambulance Fee Schedule be updated each year to reflect inflation.  This update is referred to as the “Ambulance Inflation Factor” or “AIF”.

The AIF is calculated by measuring the increase in the consumer price index for all urban consumers (CPI-U) for the 12-month period ending with June of the previous year.  Starting in calendar year 2011, the change in the CPI-U is now reduced by a so-called “productivity adjustment”, which is equal to the 10-year moving average of changes in the economy-wide private nonfarm business multi-factor productivity index (MFP).  The MFP reduction may result in a negative AIF for any calendar year.  The resulting AIF is then added to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.

For the 12-month period ending in June 2020, the federal Bureau of Labor Statistics (BLS) has calculated that the CPI-U has increased by 0.646%.

Cautionary Note Regarding CPI-U.  Members should be advised that the BLS’ calculations of the CPI-U are preliminary, and may be subject to later adjustment.  Therefore, it is possible that these numbers may change.

CMS has yet to release its estimate for the MFP for calendar year 2021.  Since its inception, this number has fluctuated between 0.3% and 1.2%.  For calendar year 2020, the MFP was 0.7%.  Under normal circumstances, it would be reasonable to expect the 2021 MFP to be within a percentage point or two of the 2020 MFP.  However, the economic impact of the COVID-19 pandemic makes predictions on the MFP difficult at this point.

Accordingly, the AAA is not in a position to confidently project the 2021 Ambulance Inflation Factor at this point in time.  However, the relative low increase in the CPI-U strongly suggests that the 2021 Ambulance Inflation Factor will be significantly lower than last year’s increase of 0.9%.

The AAA will notify members once CMS issues a transmittal setting forth the official 2021 Ambulance Inflation Factor.

 

 

Department of Health and Human Services Extends Deadline to Apply for Provider Relief Funds

Written by Brian Werfel on . Posted in Advocacy Priorities, Government Affairs, News, Regulatory.

The Department of Health and Human Services (HHS) recently announced that it would be extending the deadline for health care providers to apply to receive general distribution funding from the HHS Provider Relief Fund.  The deadline to apply for these funds was previously June 3, 2020.

Relevant Background

On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).  As part of that Act, Congress allocated $100 billion to the creation of a “CARES Act Provider Relief Fund,” which will be used to support hospitals and other healthcare providers on the front lines of the nation’s coronavirus response.  An additional $75 billion was allocated as part of the Paycheck Protection Program and Health Care Enhancement Act, bringing the total “Provider Relief Fund” up to $175 billion.  This $175 billion will be distributed to health care providers and suppliers to fund healthcare-related expenses or to offset lost revenue attributable to COVID-10.

HHS ultimately elected to allocate these funds through a $50 billion “general allocation,” and multiple smaller “targeted allocations.”

Under its general allocation program, HHS intended to provide health care providers with funds roughly equal to 2% of the provider’s 2018 “net patient revenue,” i.e., the provider’s total revenues from patient care minus provisions for bad debt, contractual write-offs, and certain other adjustments.   This general allocation was made in two tranches, with the first tranche being distributed to all providers in mid-April.  This first tranche was made based on provider’s 2019 Medicare revenues.  As a result, any provider that received payments from the Medicare Fee-for-Service Program in 2019 automatically received an initial relief payment.  However, HHS required providers to submit an application to receive relief funding as part of the second tranche.  The deadline for applying for the second tranche of relief funding was June 3, 2020.

Scope of New Extension

 HHS indicated that the new extension is limited to health care providers that missed the June 3, 2020 deadline to apply for the second tranche of relief funding.  The extension also applies to providers that were ineligible for the first tranche of relief funding due to a recent change of ownership.  The specific situations that HHS indicated would meet the requirements for the extension include:

  • Health care providers who were ineligible for the first tranche of relief funding because: (1) they underwent a change in ownership in calendar year 2019 or 2020 under Medicare Part A and (2) did not have Medicare Fee-for-Service revenues in calendar year 2019;
  • Health care providers who received a payment in the first tranche of funding but: (1) missed the June 3, 2020 deadline to submit revenue information or (2) did not receive funds in the first tranche that total approximately 2% of their net patient revenue; or
  • Health care providers who received a payment in the first tranche of funding, but who ultimately elected to refund that payment (e.g., because they did not believe they met the eligibility requirements), and who are now interested in reapplying.

Health care providers that meet one of the requirements listed above will have until August 28, 2020 to submit an application for additional relief funds.  This deadline aligns with the extended deadline for other eligible Phase 2 providers, such as Medicaid, Medicaid Managed Care, CHIP, and dental providers.

Applications should be submitted through the CARES Provider Relief Fund webpage, which can be found at: https://cares.linkhealth.com/#/.

CMS Updates Cost Data Collection FAQs and Data Collection Instrument

Written by Kathy Lester on . Posted in Operations, Patient Care.

The Centers for Medicare & Medicaid Services (CMS) has released printable version of the ground ambulance data collection instrument and an expanded FAQ. Both updated documents address some of the more common questions that CMS has heard over the past months, many of which the American Ambulance Association raised.  Importantly, CMS announces through the FAQs the registration process will begin December 2021.

The topics covered in the FAQs include:

  • General questions related to the rationale for collecting data, definitions, and how the information will be used and reported;
  • Sampling and notification questions related to how ground ambulance organizations will be selected to participate in the data collection system;
  • Data collection and reporting timelines and effort questions, which focus on the timelines for collecting and reporting the information, as well as the projected effort required;
    • There are three new FAQs in this section about the impact of the delay due to the pandemic (the questions and answers are below)
  • Requirement to report questions, which focus on the types of information that must be reported and responding to requests from MACs;
    • There is a new FAQ in this section about applying for a hardship exemption (the questions and answers is below)
  • Reporting information questions, which include who within an organization should report the information, the data tool, and how to address technical problems;
    • There are two new FAQ in this section about the pause in data collection due to the pandemic (the questions and answers are below)
    • Importantly, CMS announces that the registration will begin December 2021
  • Data collection scope and principles questions, which discuss the specific type of information and level of specificity that is required;
    • There are several new FAQs in this section about using current accounting practices, municipality practices, and accounting good and services provided by another organization (the questions and answers are below)
  • Reporting information on staffing and labor costs questions, which address issues such as volunteer staff, staff with multiple duties, calculating hours worked;
    • There are three new FAQs in this section about total hours worked, staff training, and paid time off (the questions and answers are below)
  • Reporting other information, such as service area, service mix/service volume, facilities, vehicles, equipment/supplies, and revenue.


New FAQs

 Question: Will the modification listed in the COVID-19 Emergency Declaration Blanket Waiver issued by CMS on May 15, 2020 allow ground ambulance organizations selected in year 1 the 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? [Added 7/31/2020]

    • Answer: No. The ground ambulance organizations that were selected in year 1 do not have an option and must select a new data collection period starting in 2021. CMS cannot permit this option because the data collected in 2020 during the public health emergency may not be reflective of typical costs and revenue associated with providing ground ambulance services.
  • Question: When will sampled organizations report information? [Updated 7/31/2020]
    • Answer: Sampled organizations will report information within a 5-month reporting period that starts at the end of the organization’s collection period. For example, if your organization begins collecting information on January 1, 2021, your organization’s collection period will run until December 31, 2021 and your organization must report information during the 5- month period between January 1, 2022 and May 31, 2022.
  • Question: How are data collection and reporting dates adjusted for organizations selected in Year 1 given the modification listed in the CMS COVID-19 Emergency Declaration Blanket Waiver? [Added 7/31/2020]
    • Answer: CMS issued a COVID-19 Emergency Declaration Blanket Waiver delaying data collection and reporting requirements for ground ambulance organizations selected in Year 1 by one year. The organizations selected in Year 1 will now collect data during a continuous 12-month period starting in 2021 (rather than 2020) and will now report information during a 5-month period starting in 2022 (rather than 2021). As an example, a Year 1 organization that previously would have collected information from January 1, 2020 to December 31, 2020 and reported information between January 1, 2021 to May 31, 2021 will now collect information from January 1, 2021 to December 31, 2021 and report information between January 1, 2022 and May 31, 2022. Organizations in the Year 1 sample will not report any information collected to date in 2020.
  • Question: Can you provide examples of different data collection periods and the data reporting periods depending on my accounting period start date? [Updated 7/31/2020]
    • Answer: Example of a Data Collection and Reporting Period for a Ground Ambulance Organization with a Calendar Year Accounting Period:

Examples of Data Collection and Reporting Periods for a Ground Ambulance Organization with Accounting Period not based on a Calendar Year:

  • Question: Can my organization request a hardship exemption from the payment reduction? [Updated 7/31/2020]
    • Answer: Yes. Organizations that did not report sufficient data due to a significant hardship, such as a natural disaster, bankruptcy, or other similar situations may request a hardship exemption. To request a hardship exemption after the ground ambulance organization receives notification that it will be subject to the 10 percent payment reduction as a result of not sufficiently submitting information under the data collection system, organizations should complete a request form that will be available at the end of the data reporting period on CMS’s Ambulances Services Center website at https://www.cms.gov/Center/Provider- Type/Ambulances-Services-Center.html. Organizations can request a hardship exemption within 90 calendar days of the date that CMS notified the organization that it would receive a 10 percent payment reduction as a result of not submitting sufficient information under the data collection system. Your organization will be asked to supply information such as reason for requesting a hardship exemption, evidence of the hardship (e.g., photographs, newspaper, other media articles, financial data, bankruptcy filing, etc.), and date when your organization would be able to begin reporting information. All hardship exemption requests will be evaluated based on the information submitted that clearly shows that they are unable to submit the required data.
  • Question: Where and how does my organization report information? [Updated 7/31/2020]
    • Answer: No information will be reported until 2022. As we stated in the CY 2020 Physician Fee Schedule Final Rule (84 FR 62867), a secure web-based data collection system will be available before the start of your data reporting period to allow time for users to register, receive their secure login information, and receive training from CMS on how to use the system. CMS will provide separate instructions on how to access the online Ground Ambulance Data Collection System. You can view a printable version of the ground ambulance data collection instrument at: https://www.cms.gov/Center/Provider- Type/Ambulances-Services-Center for the data collection requirements.
  • Question: My organization was selected in the first group to collect and report cost and other required data. When will we be able to register for the data collection system? [Updated 7/31/2020]
    • Answer: Registration for the system will begin in December 2021. Please check the Medicare Ambulance Services Center website at https://www.cms.gov/Center/Provider- Type/Ambulances-Services-Center.html for updates.
  • Question: Can my organization collect information using our current accounting practices? [Added 7/31/2020]
    • Answer: In general, you will be able to report information collected under your organization’s current accounting practices. CMS understands that some ground ambulance organizations use accrual-basis accounting while others use cash-basis accounting. Please follow the instructions in each instrument section.
  • Question: My ground ambulance organization is owned and/or operated by our local municipality. The municipality pays directly for some costs associated with our ground ambulance operations (e.g., facilities costs, utilities, fuel, benefits, etc.). Do we need to report on these costs? [Updated 7/31/2020]
    • Answer: Yes. You must work with your municipality to report the costs that are relevant to your ground ambulance service. Otherwise, the costs that you report will be incomplete and not reflect your organization’s total costs. This would also apply if your ground ambulance organization is part of a broader organization that pays directly for some of your organization’s costs (e.g., a hospital Medicare provider that also owns and provides ground ambulance services). The specific information that you will need to collect and report might include information on labor costs (Section 7); facilities costs (Section 8); Vehicle costs (Section 9); equipment, consumable, and supply costs (Section 10), and other costs (Section 11). If you are a fire, police, or other public safety-based ground ambulance organization, please report labor hours and compensation associated with both ground ambulance and other public safety roles per the data collection instrument instructions.
  • Question: How should we account for goods or services provided by another organization (e.g., hospital, local government)? [Added 7/31/2020]
    • Answer: Whether and how to account for costs realized by an entity other than your ground ambulance organization depends on the nature of the relationship with the other entity. CMS has heard that it is relatively common for some costs – for example dispatch, vehicle maintenance, or administrative costs – to be borne by an organization’s local municipality or a part of a local municipal government (such as a police department):
    • If your ground ambulance organization is part of or associated with a local municipality, you need to report these costs. For example, if dispatch services are provided by your municipality’s police department and your ground ambulance organization is part of or associated with the same municipality, then you must collect and report a share of dispatch costs associated with ground ambulance operations. See the related question “My ground ambulance organization is owned and/or operated by our local municipality. The municipality pays directly for some costs associated with our ground ambulance operations (e.g., facilities costs, utilities, ambulance fuel, benefits, etc.). Do we need to report on these costs?”
    • If your ground ambulance organization is NOT part of (i.e., owned or operated by) a local municipality, you do NOT need to report costs associated with services provided by your local municipality other than costs (if any) paid directly by your organizations for the service. If your municipality provides dispatch services for your community and your organization does not pay for this service, then no costs related to dispatch are reported. See the related question “My organization received donations during the data collection period (e.g., an ambulance donated by the community, medicines or medical consumables provided by hospitals, or cash donations). How should these donations be reported?” If your organization makes a payment in exchange for a service, report the payment as a cost under the appropriate section of the data collection instrument.

The same principles apply to similar cases, for example when the other entity is a hospital, non-profit organization, or other type of entity.

  • Question: Should hours on call be included in total hours worked? [Added 7/31/2020]
    • Answer: When reporting hours worked, whether for paid or volunteer staff, do not include hours on call toward hours worked.
  • Question: How should we report staff training in the data collection instrument? [Added 7/31/2020]
    • Answer: There are two ways that you can report training. If training is conducted by your organization’s staff, you would include hours worked and compensation for training staff in your calculations of total hours worked and total compensation. Employees would report hours spent and compensation (if any) for attending trainings. If the training is not just on ground ambulance topics, the reported total hours and compensation would reflect an estimate the percent of time related to ground ambulance. If you have other training expenses or pay money to an outside organization for training activities, these can be listed in Section 11, Question 3 under the category “Training and continuing education costs (e.g., costs for materials, travel, training fees, and labor).” Costs related to collecting and reporting data to the Medicare Ground Ambulance Data Collection System should not be reported.
  • Question: How should we report paid time off (PTO) in the data collection instrument? [Added 7/31/2020]
    • Answer: Paid time off (PTO) is not included in the hours worked section in the labor portion of the data collection instrument. However, PTO is a benefit that should be included in the total compensation questions of the labor section.
  • Service Area: Question: How should our organization define the primary and secondary service area for our particular circumstances? [Updated 7/31/2020]
    • Answer: For the purposes of this data collection effort, use your best judgement. In general, your primary service area is the area in which you are exclusively or primarily responsible for providing service at one or more levels and where it is highly likely that the majority of your transport pickups occur. A secondary service area is outside your primary service area, but one where you regularly provide services through mutual or auto-aid arrangements or at a different level of service compared to your primary service area. When reporting service areas using ZIP codes, it is possible that you will report the same ZIP code as belonging to both your primary and secondary service area, for example in a case where a town and a township share a ZIP code and your organization is primarily responsible for service within the town but has mutual or auto aid agreements with the surrounding township. Please list all ZIP codes in your service area, even if they cross over into another county or municipality. For the service volume section of the instrument, responses, transports, etc. to both primary and secondary service areas should be included in the totals reported.
  • Service Mix/Service Volume: Question: How should my organization count ground ambulance responses and/or transports if more than one vehicle is sent to the scene or if more than one patient is transported? [Added 7/31/2020]
    • Answer: If more than one vehicle is sent to the scene, count this as one response. Organizations should count the total number of patients transported. A single response may result in multiple transports in cases where multiple ambulances are deployed or when multiple patients are transported by the same ambulance.
  • Question: How should our organization report on situations where we respond to calls for service in conjunction with staff from another organization? [Added 7/31/2020]
    • Answer: In Section 5, Question 3, you can report that your organization responds to calls for service in conjunction with vehicles and/or staff from another organization. You must report payments that you make to the other organization (as “other costs” in Section 11) and payments received by your organization (as revenue in Section 13). You will not need to report specific labor or other costs from the other organization. Report the total revenue that your organization receives from payers and other sources, even if you later share the revenue with the other organization.
  • Facilities: Question: My organization does not record buildings as assets or calculate depreciation for buildings. Do we need to report depreciation for buildings? [Added 7/31/2020]
    • Answer: No.
  • Vehicles: Question: How should we calculate annual depreciation expenses for vehicles and capitalized equipment? [Updated 7/31/2020]
    • Answer: In general, you will be able to use your organization’s standard approach to calculating depreciation expenses. If your organization calculates depreciation expense for multiple purposes (e.g. depreciation for tax incentive purposes vs. Generally Accepted Accounting Principles (GAAP) for standard auditing purposes), please report the depreciation expense captured for standard auditing purposes. There are several presentations, such as the December 5, 2019 National Provider Call, that provide examples of reporting annual depreciation expenses in Section 8 (Facilities Costs), Section 9 (Vehicle Costs), and Section 10 (Equipment, Consumable, and Supply Costs) of the data collection instrument. These presentations are available on the Ambulances Services Center website at https://www.cms.gov/Center/Provider-Type/Ambulances-Services-Center.html.
  • Equipment: Question: My organization uses a cash basis for accounting and does not depreciate equipment or supplies. Do we need to start calculating annual depreciation? [Added 7/31/2020]
    • Answer: No. If your department is a cash basis entity and doesn’t calculate depreciation, you do not have to report depreciation. Please report the entire purchase costs in the relevant sections.
  • Revenue: Question: How is revenue defined for the purposes of collecting and reporting data? [Added 7/31/2020]
    • Answer: Report gross/total revenue received from all sources during the data collection period. You may need to collect information from a billing company or your municipality in order to report this information. Do not report charges, billed amounts, or bad debt. Depending on your organization’s accounting practices, CMS understands that the revenue received during the data collection period may not perfectly align with the services provided during the data collection period.
  • Question: My organization is unable to separate revenue from payers related to transports and non-transport services. How should we report revenue for non-transport services? [Added 7/31/2020]
    • Answer: If possible, report only revenue from transports in Section 13, Questions 2-4. Report revenue from non-transport EMS and ground ambulance services in Section 13, Question 5.
  • Question: My organization shares revenue from billed service with another organization. Should we report the revenue we receive from payers or the share we retain? [Added 7/31/2020]
    • Answer: Report the revenue that you initially receive from payers. Do not subtract the amount that you share with another organization. Report the amount you do share in Section 11 (“Other Costs”) as a cost.

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