AAA Sends letter on Accelerated Payments

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

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

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

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

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

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

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

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

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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Proposed Rule Impacts Employer Sponsored Health Plans

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

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

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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HHS OIG Issues Advisory Opinion on Community Paramedicine

HHS OIG Issues Advisory Opinion Permitting Community Paramedicine Program Designed to Limit Hospital Readmissions On March 6, 2019, the HHS Office of the Inspector General (OIG) posted OIG Advisory Opinion 19-03. The opinion related to free, in-home follow-up care offered by a hospital to eligible patients for the purpose of reducing hospital admissions or readmissions. The Requestor was a nonprofit medical center that provides a range of inpatient and outpatient hospital services. The Requestor and an affiliated health care clinic are both part of an integrated health system that operates in three states. The Requestor had previously developed a program to provide free, in-home follow-up care to certain patients with congestive heart failure (CHF) that it has certified to be at higher risk of admission or readmission to a hospital. The Requestor was proposing to expand the program to also include certain patients with chronic obstructive pulmonary disease (COPD). According to the Requestor, the purpose of both its existing program and its proposed expansion was to increase patient compliance with discharge plans, improve patient health, and reduce hospital inpatient admissions and readmissions. Under the existing program, clinical nurses screen patients to determine if they meet certain eligibility criteria. These include...

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Release: CMMI Announces Ambulance Innovative Payment Pilot Program

February 14, 2019 For Immediate Release Contact Maria Bianchi American Ambulance Association 202-802-9020 info@ambulance.org CMMI Announces Ambulance Innovative Payment Pilot Program Washington, DC – Today, the Centers for Medicare & Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) announced the launch of the Emergency Triage, Treat and Transport (ET3) Model.  During the next five years, this model will test paying ambulance providers and suppliers when they transport beneficiaries to locations other than an emergency department, if the alternative location is more appropriate medically for the patient.  It will also test paying for health care services provided by qualified health care professionals or through telehealth at the scene even if the ambulance does not transport the patient. While there are several important details yet to be released, this model appears to track the recommendations the American Ambulance Association, our members, and other industry partners have been working with CMS to implement. “Over the last 7 years, the AAA and our members have been working to develop an innovative payment framework to modernize the Medicare ambulance benefit,” said AAA President Aarron Reinert. “We are pleased that CMS is taking this important step and look forward to working closely with Administrator (more…)

HHS OCR Requests Feedback on HIPAA Privacy Rule

On January 28, 2019, the Office of Health and Human Services the Office for Civil Rights (HHS OCR) issues a Request for Information (RFI) seeking input from covered entities regarding several aspects of the Health Insurance Portability and Accountability Act (HIPAA).  Specifically, the HHS OCR is seeking input regarding several elements of the Privacy Rule, including the following: Encouraging information-sharing for treatment and care coordination Facilitating parental involvement in care Addressing the opioid crisis and serious mental illness Accounting for disclosures of PHI for treatment, payment, and health care operations as required by the HITECH Act Changing the current requirement for certain providers to make a good faith effort to obtain an acknowledgment of receipt of the Notice of Privacy Practices I am aware that several AAA member services who have struggled with many of the HIPAA restrictions regarding the sharing of PHI with other healthcare entities.  In particular, with regard to individuals who suffer opioid overdoses and efforts to ensure the individual has access to drug treatment programs.  Additionally, HHS OCR is seeking input from covered healthcare providers regarding the “good faith” efforts to obtain acknowledgement of the receipt of Privacy Practices.  This has been a considerable challenge for...

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Update on HHS OIG Reports on Ambulance Services

Update on HHS Office of the Inspector General Reports on Ambulance Services The HHS Office of the Inspector General (OIG) released an update to the Work Plan as the year comes to a close.  There are no new projects specific to ambulance services, but the update does provide a summary of three projects that have been completed or are in progress. Medicare Part B Payments for Ambulance Services Subject to Part A Skilled Nursing Facility Consolidated Billing Requirements (expected release 2019). In this work, the OIG  seeking to determine whether ambulance services paid by Medicare Part B were subject to Part A SNF consolidated billing requirements. The OIG will also assess the effectiveness of edits in CMS’s Common Working File to prevent and detect Part B overpayments for ambulance transportation subject to consolidated billing. Prior OIG reports have identified high error rates and significant overpayments for services subject to SNF consolidated billing. Ambulance Services – Supplier Compliance with Payment Requirements (partially completed; remainder expected release 2019). Prior OIG work has found that Medicare made inappropriate payments for advanced life support emergency transports. The OIG seeks to determine whether Medicare payments for ambulance services were made in accordance with Medicare requirements. ...

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Federal District Court Judge Strikes Down the ACA

On December 14, 2018, a federal district court judge for the Northern District of Texas issued a ruling striking down the Affordable Care Act (ACA) on the grounds that the Individual Mandate was unconstitutional, and that the rest of the law cannot withstand constitutional scrutiny without the Individual Mandate. District Court Judge Reed O’Connor’s decision relates to a lawsuit filed earlier this year by 20 states and two individuals. The plaintiffs argued that the Tax Cuts and Jobs Act of 2017 — which amended the Individual Mandate to eliminate the penalty on individuals that failed to purchase qualifying insurance effect January 1, 2019 — rendered the Individual Mandate unconstitutional. The plaintiffs further argued that the Individual Mandate was inseverable from the rest of the ACA, and, therefore, that the entire ACA should be struck down. The defendants in this case were the United States of America, the U.S. Department of Health and Human Services (HHS), Alex Azar, in his capacity as the Secretary of HHS, and David J. Kautter, in his capacity as the Acting Commissioner of the Internal Revenue Service (IRS). 16 states and the District of Columbia intervened as additional defendants. In order to properly understand the district (more…)