HHS Report Calls for Congressional Action to Combat Surprise Billing

Posted on July 29, 2020 by AAA Staff

From HHS.gov on July 29, 2020 HHS Secretary’s Report Calls for Congressional Action to Combat Surprise Billing and Promote Price Transparency Today, the U.S. Department of Health and Human Services released the HHS Secretary’s Report on Addressing Surprise Billing. The report, called for in Section 7 of President Trump’s Executive Order 13877, Improving Price and Quality Transparency in American Healthcare to Put Patients First, outlines critical steps, including Congressional action, to implement the Administration’s principles on surprise billing. Sound surprise billing legislation will not only protect patients but will encourage a fairer, more transparent, patient-centered healthcare system that benefits all Americans. “Americans have the right to know what a healthcare service is going to cost before they receive it,” said HHS Secretary Alex Azar. “President Trump and his administration have done their part to deliver historic transparency around the prices of many procedures. Now it’s time for Congress to do what we all agree is necessary: combat surprise billing with an approach that puts patients in control and benefits all Americans.” Surprise medical billing is a widespread and costly problem in the United States, and the need to address it has been highlighted during the Public Health Emergency (PHE) presented by COVID-19. Research (more…)

HHS | Post-Payment Notice of Reporting Requirements

Posted on July 24, 2020 by AAA Staff

From HHS on July 20, 2020 General and Targeted Distribution Post-Payment Notice of Reporting Requirements July 20, 2020 Purpose The purpose of this notice is to inform Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing of future reporting requirements. Detailed instructions regarding these reports will be released by August 17, 2020. Overview Congress appropriated funding to reimburse eligible health care providers for health care related expenses or lost revenues attributable to coronavirus. The Health Resources and Services Administration (HRSA) is administering the distribution of payments under the PRF program, funded through appropriations in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) and the Paycheck Protection Program and Health Care Enhancement Act (P.L. 116-139). Each recipient of a payment from the PRF that used any part of that payment agreed to a set of Terms and Conditions (T&Cs) which, among other obligations, require each recipient to submit reports to the Department of Health and Human Services (HHS). The reports shall be in such form, with such content, as specified by the Secretary of HHS in future program instructions directed to all recipients. HHS will (more…)

HHS Renews the Declaration of a Public Health Emergency

OCR Issues Guidance on Civil Rights Protections Prohibiting Race, Color, and National Origin Discrimination During COVID-19

Posted on July 22, 2020 by AAA Staff

News Release from the U.S. Department of Health and Human Services | Monday, July 20, 2020 OCR Issues Guidance on Civil Rights Protections Prohibiting Race, Color, and National Origin Discrimination During COVID-19 Yesterday, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) is issuing guidance to ensure that recipients of federal financial assistance understand that they must comply with applicable federal civil rights laws and regulations that prohibit discrimination on the basis of race, color, and national origin in HHS-funded programs during COVID-19. This Bulletin focuses on recipients’ compliance with Title VI of the Civil Rights Act of 1964 (Title VI). To help ensure Title VI compliance during the COVID-19 public health emergency, recipients of federal financial assistance, including state and local agencies, hospitals, and other health care providers, should: Adopt policies to prevent and address harassment or other unlawful discrimination on the basis of race, color, or national origin. Ensure – when site selection is determined by a recipient of federal financial assistance from HHS – that Community-Based Testing Sites and Alternate Care Sites are accessible to racial and ethnic minority populations. Confirm that existing policies and procedures with respect to COVID-19 (more…)

On Demand Presentation: Emergency Medical Services and 911

Posted on June 3, 2020 by AAA Staff

Healthcare Resilience Task Force: EMS/911 May 29, 2020 Dr. Jon Krohmer, NHTSA, HRTF EMS/Pre-hospital Team Lead Kate Elkins, NHTSA, HRTF EMS/Pre-hospital Deputy Team Lead 911, the universal number to call for emergency help nationwide, is a proven, life-saving service to the public. NHTSA’s Office of EMS oversees the National 911 Program, which envisions an emergency response system that best serves the public, providing immediate help in all emergency situations. This presentation covered the current Emergency Medical Services (EMS) Environment, Impacts and Next Steps for EMS in regards to COVID-19, and EMS and Fire Impacts on Community Lifelines.

AAA Sends letter on Accelerated Payments

Posted on May 27, 2020 by AAA Staff

On May 26, the AAA sent a letter to HHS Secretary Alex Azar and CMS Administrator Seema Verma, requesting improvements to the Medicare Accelerated and Advance Payment (MAAP) Programs. The nation’s response to the COVID-19 pandemic is putting an increased financial strain on emergency medical services, and ground ambulance service providers and suppliers already faced significant funding challenges. The suggested improvements include: Extending the interim period prior to the date repayment begins from four months to at least 12 months; Reducing the amount that is withheld during the repayment period from one hundred percent (100%) of the Medicare payment to not more than twenty-five percent (25%); Extending the date on which interest first begins to accrue from 210 days to at least 2 years (preferably 3 years); Reduce the interest rate that would be applicable after that date from the current 9.625 percent to a rate of no more than 2%; and Reopen the MAAP to allow EMS agencies that did not request a Medicare advance prior to April 26, 2020 to request an advance. The AAA believes the improvements to the MAAP discussed above would provide short-term financial relief to ambulance service providers and suppliers nationwide and allow us...

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CMS Issues Additional Staffing and Licensing Waivers

Posted on May 7, 2020 by Brian Werfel

On May 1, 2020, CMS updated its “COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing.” The full document can be viewed by clicking here. In the updated FAQ, CMS answers three important questions related to ambulance vehicle and staffing requirements: Expired Ambulance Operating Licenses. CMS was asked whether a ground ambulance vehicle operating under an expired license could nevertheless satisfy the Medicare regulations related to vehicle licensing. CMS indicated that the ground ambulance would remain in compliance with Medicare Program rules to the extent it was permitted to operate without a renewed license under a valid state or local law, regulation, or legally adequate waiver. It is important to note that this is not a “waiver” of CMS rules per se. Rather, CMS correctly noted that additional flexibility being provided is based on the state waiving or relaxing its existing rules related to licensures. Modified Staffing Requirements. CMS was asked whether an ambulance service that staffs its vehicles with personnel that fall below the previously required levels of certification would be in compliance with Medicare Program rules. The Medicare regulations at 42 C.F.R. §410.41(b) set forth the requirements for vehicle staffing. These regulations largely defer to state and...

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COVID-19 Uninsured Program Now Includes Air, Water

Posted on May 5, 2020 by Brian Werfel

HHS Updates Guidance on Provider Relief Funding for Uninsured to include Air and Water Ambulance The Department of Health and Human Services recently updated its guidance on the disbursement of provider relief funds under the CARES Act for the testing and treatment of the uninsured. Previously, HHS indicated that this allocation was only available for the reimbursement of emergency and non-emergency ground ambulance transportation. However, in its most recent update, HHS has removed the restriction that limited participation to ground ambulance providers and suppliers. The new guidance indicates that the relief funds are now available for all emergency ambulance transportation and non-emergency patient transfers via ambulance. Thus, it appears that air and water ambulance providers and suppliers are now eligible to receive funding for the treatment of COVID-19 patients. Is there anything my air or water ambulance organization needs to do to claim reimbursement for treatment of uninsured COVID patients? Yes. In order to be eligible for payments for the treatment of uninsured COVID patients, you must enroll as a participant in the program. Enrollment must be done through an online portal that can be accessed at: http://www.coviduninsuredclaim.hrsa.gov. Once my organization enrolls, when can we start submitting claims for reimbursement...

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COVID-19 Financial Impact Calculator

Posted on April 28, 2020 by AAA Staff

The American Ambulance Association is working nonstop on advocating for financial relief from the impact of the Coronavirus (COVID-19) for our members. Now that ground ambulance service providers and suppliers are receiving federal funding to help partially offset the negative financial impact of the Coronavirus (COVID-19), the Congress is asking for information to substantiate that additional funding is necessary. Instead of providing just anecdotal information on the increased costs and lost revenue from COVID-19, we need to provide more wide-ranging data demonstrating the dire financial situation facing our industry. To this end, the American Ambulance Association has developed a Financial Impact Calculator to gather information from our members to help us make our case for additional financial relief. The Calculator is also designed for members to use in completing the application for more funding under the General Allocation second distribution of the Public Health and Social Services Emergency Fund. Download the Excel Version of the Financial Impact Calculator as a reference. The Instructions include definitions for fields in both the Excel and online calculators. Your data will be safely stored, and will be shared only in aggregate. Please DO NOT enter commas or dollar signs when providing data. The system will (more…)

HHS Provider Relief Tranche 2 Calculator

Posted on April 28, 2020 by Amanda Riordan

Use the American Ambulance Association’s simple form to estimate relief you may receive from the second tranche of HHS COVID-19 funding. Please note that not all providers will receive funds. More information about this program as well as access to the form you must complete in the General Allocation Portal can be found on the HHS website. For-profit and non-profit non-governmental providers, to determine your Net Patient Revenue for the portal, use the following information from your most recently filed tax return. (2019 if filed, otherwise use 2018 numbers). Governmental providers, enter your revenue generated for the last audited financial year. When completing the form in the portal, select Tax Exempt Organization. When asked to upload a return at the end, upload your most recent audited financials. Please do not enter commas or dollar signs. A negative number or zero in the Tranche 2 box indicates that you WILL NOT receive funding in tranche 2....

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UPDATED: What to Do for Round 2 of HHS Provider Relief

Posted on April 24, 2020 by Brian Werfel

UPDATED: HHS Opens Portal for Healthcare Providers and Suppliers to Apply for Second Tranche of CARES Act Provider Relief Funding Updated April 24, 2020 at 9:40 pm | Register for AAA’s 4/27 webinar on this topic► At 5 p.m. on Friday, April 24, 2020, the Department of Health and Human Services opened the online portal that health care providers and suppliers must use to submit their revenue information. This is a requirement to access the second $20 billion tranche of general allocation funding. Access the online portal► In order to provide the required information, you will need the following information/documentation: Your Tax Identification Number (TIN) The bank account to which the first tranche of provider relief funding You will need access to the email account that you are using to apply for funds (to accept and provide back a security verification code) A PDF copy of your most recent tax return The portal will ask a series of questions to verify your identity and the identity of your organization. These include providing your TIN and the last six digits of the bank account to which the original tranche of relief funding was provided. After completing the verification process, you will...

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CMS Office Hours on COVID-19

Posted on April 16, 2020 by AAA Staff

CMS Office Hours on COVID-19 You are invited to CMS “Office Hours” on COVID-19, today, Thursday, April 16th from 5:00 – 6:00 PM Eastern, the next in a series of opportunities for hospitals, health systems, and providers to ask questions of agency officials regarding CMS’s temporary actions that empower local hospitals and healthcare systems to: Increase Hospital Capacity – CMS Hospitals Without Walls; Rapidly Expand the Healthcare Workforce; Put Patients Over Paperwork; and Further Promote Telehealth in Medicare Dial-in details below. Conference lines are limited, so we highly encourage you to join via audio webcast, either on your computer or smartphone web browser. You are welcome to share this invitation with your colleagues and membership. Toll-Free Attendee Dial In: 833-614-0820 Event Plus Passcode: 6168487 Audio Webcast link You can find a copy of the full press release and related materials HERE To keep up with the important work the White House Task Force is doing in response to COVID-19, please click here: www.coronavirus.gov. For information specific to CMS, please visit the Current Emergencies Website....

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Technical Resources from HHS/ASPR TRACIE to Assist First Responders and Healthcare Providers

Posted on April 16, 2020 by AAA Staff

Technical Resources from HHS/ASPR TRACIE to Assist First Responders and Healthcare Providers HHS ASPR, the Technical Resources, Assistance Center, and Information Exchange (TRACIE) was created to meet the information and technical assistance needs of regional ASPR staff, healthcare coalitions, healthcare entities, healthcare providers, emergency managers, public health practitioners, and others working in disaster medicine, healthcare system preparedness, and public health emergency preparedness. As we continue to work with each other through the COVID-19 response, we would like to share some resources to assist your efforts as first responders and healthcare providers in these challenging times. The documents listed below will serve to assist you and your colleagues should you ever need guidance on best practices and any issue related to the COVID-19 response. Death of a Colleague During the COVID-19 Pandemic: Understanding and Managing Grief for Healthcare Workers and Leaders Overview of recent federal guidance and resources to hospitals, inpatient and outpatient facilities, and alternate care strategy sites experiencing the loss of a fellow healthcare co-worker during COVID-19; Guidance for healthcare workers and leaders with strategies to address grief and facilitate emotional recovery in the workforce Grief Following Patient Deaths During COVID-19: Tips for Healthcare Workers in Managing Grief Grief...

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AAA Sends Letter to HHS on COVID-19 Response

Posted on April 7, 2020 by AAA Staff

On April 6, the AAA sent a letter to Health and Human Services Secretary Azar requesting that the Department distribute direct payments to all ambulance service providers and suppliers who are on the front lines of the COVID-19 pandemic. The AAA requested funding under the $100 Billion Public Health and Social Service Emergency Fund, established by the CARES Act, in the amount of $48,000 per ambulance registered as of April 1. The AAA estimates the payments would represent approximately $2.6 billion in desperately-needed relief for our industry. Read the letter HERE....

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HHS Notice on Hoarding Supplies

OCR Guidance on COVID-19 and HIPAA Disclosures

HHS OCR COVID-19 HIPAA Guidance for EMS

Proposed Rule Impacts Employer Sponsored Health Plans

Posted on December 5, 2019 by Scott Moore

A proposed rule published on November 27th by the IRS, U.S. DOL, and HHS would place new requirements on group health plans and health insurance providers. The rule would require providers to disclose cost-sharing information to participants, beneficiaries, and other covered individuals which would outline their liability to pay certain cost-sharing amounts and out-of-pocket expenses. This rule is part of a Trump Administration effort to foster competition among insurers and healthcare providers in the marketplace. An article published by the Society for Human Resources Management (SHRM) outlines the concerns many employers have regarding the costs associated with implementing the requirements of the proposed rule. These requirements include providing plan enrollees with an online self-service portal where they can see these cost-sharing amounts, as well as require greater collaboration between third party plan administrators, pharmacy benefit managers, and other specialty providers to ensure the accurate disclosure of enrollee financial obligations. Comments on the proposed rule are due by January 14, 2020....

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HHS OIG Issues Proposed AKS Safe Harbor Rule

Posted on October 28, 2019 by Brian Werfel

On Thursday, October 17, 2019, the HHS Office of the Inspector General (OIG) issued a proposed rule titled “Medicare and State Health Care Programs: Fraud and Abuse; Revisions to Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalties Regarding Beneficiary Inducements.” The proposed rule would amend the existing safe harbors to the Federal Anti-Kickback Statute (AKS) and the civil monetary penalty rules (CMPs). These changes are part of HHS’ Regulatory Sprint to Coordinated Care. The stated purpose of these changes is to reduce the regulatory barriers and accelerate the transformation of the healthcare system away from the traditional fee-for-service payment model, and towards a value-based system that rewards healthcare providers for better outcomes. The proposed rule can be viewed in its entirety at: https://www.govinfo.gov/content/pkg/FR-2019-10-17/pdf/2019-22027.pdf. The proposed rule makes nearly a dozen major changes to the safe harbors under the AKS and the rules related to CMPs. Among these are revisions to the recently created safe harbor for local transportation. The proposed change to the safe harbor for free or discounted local transportation is discussed in greater detail below. The OIG is soliciting comments on a wide range of topics raised in the proposed rule. The AAA is not taking...

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New SNF Consolidated Billing Edits: FAQs

Posted on August 20, 2019 by Brian Werfel

On April 1, 2019, CMS implemented a new series of Common Working File (CWF) edits that it stated would better identify ground ambulance transports that were furnished in connection with an outpatient hospital service that would be bundled to the skilled nursing facility (SNF) under the SNF Consolidated Billing regime. Unfortunately, the implementation of these new edits has been anything but seamless. Over the past few weeks, I have received numerous phone calls, texts, and emails from AAA members reporting an increase in the number of Medicare claims being denied for SNF Consolidated Billing. This FAQ will try to explain why you may be seeing these denials. I will also try to provide some practical solutions that can: (1) reduce the number of claims denied by the edits and (2) help you collect from the SNFs, when necessary. Please note that, at the present time, there is no perfect solution to this issue, i.e., there is nothing that you can do to completely eliminate these claim denials. The solutions discussed herein are intended only to minimize the disruption to your operations caused by these denials. I am new to Medicare ambulance billing. Can you explain what the SNF Consolidated Billing...

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