Tag: Physician Fee Schedule

CMS Releases CY 2021 Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) has released the Physician Fee Schedule Proposed Rule for Calendar Year (CY) 2021 which has traditionally included proposed changes to the Ambulance Fee Schedule for the same year. The American Ambulance Association (AAA) has confirmed with CMS that the reason there are no references to the Ambulance Fee Schedule in the Proposed Rule is because the temporary add-ons were built into the regulations themselves.  Thus, the governing regulations already indicate that the temporary add-on payments for ground ambulance transports are effective for services furnished through December 31, 2022.  The regulations are at 42 CFR §414.610 (c)(1)(ii) and 42 CFR §414.610 (c)(5)(ii).

The Proposed Rule also seeks to extend or make permanent several of the telehealth waivers CMS has implemented during the public health emergency.  Because CMS does not believe it has the authority to reimburse ambulance providers or suppliers for services provided without transportation also occurring, these waivers have not applied to ground ambulance.  However, we will review these provisions of the rule closely to identify potential opportunities to include ground ambulance providers and suppliers in these policies.

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

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

CMS Ambulance Open Door Forum

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

Questions?

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

AAA Follow Up Q&A

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

Submit Comments on Ambulance Data Collection System

Yesterday, the AAA submitted our comment letter to the proposed rule on changes for FY2020 to the Medicare ambulance fee schedule. The comment letter focused on the section of the proposed rule on the ambulance data collection system. For a copy of the detailed 28-page comment letter, please click here.

Read the AAA Comment Letter

The AAA is very pleased with the approach CMS is taking on data collection which is consistent with the intent of the Congress and the methodology developed and advocated by the AAA. While the AAA comment letter is extremely detailed, our only concern is CMS was not able to test or pilot the sampling methodology and data collection instrument prior to inclusion in the proposed rule. Testing would have allowed CMS to fine-tune the survey and may impact the quality of the first year of data.

Now, it is important that AAA members submit their own letters to demonstrate support for the AAA letter and its key points.

AAA members should go to www.regulations.gov and make three points as follows:

  • Our organization supports the approach CMS is proposing to collect ambulance data and we thank CMS and its contractors.
  • Since CMS was unable to test the sampling methodology and data collection tool, we are concerned about the potential quality of the first year of data. We therefore ask CMS to begin education of ambulance service suppliers and providers and work with the American Ambulance Association to adjust the methodology and tool, if necessary, for future data collections.
  • We fully support the specific comments submitted by the American Ambulance Association as to recommended improvements to the data collection tool.

All you need to do is click on www.regulations.gov and include the above three points. Add your first and last name and click “continue” to then finalize your submission.

The AAA has also developed a sample comment letter you can access by clicking here. Go to www.regulations.gov and instead of adding the three points in the comment back, upload your letter.  Please draft your own customized letter using the letter provided by the AAA as a guideline.

Sample Comment Letter

Comments are due by 5:00 pm on Friday, September 27, so please submit your comment letter today! Please also feel free to forward this email to state ambulance associations and other ambulance service organizations.

The AAA will be submitting a second letter in the next week just on seeking clarification around changes to PCS requirements in the proposed rule but will not be asking members to submit similar comments.

We greatly appreciate the work of CMS and its contractors in developing the ambulance data collection system.

Thank you in advance to all of you who take the time to submit comment letters.

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs
tnorth@ambulance.org | (202) 802-9025

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

Thank you for your continued membership and support.

CMS Open Door Forum & Member Q&A – August 28

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

CMS Ambulance Open Door Forum

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

Questions?

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

AAA Follow Up Q&A

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

Physician Fee Schedule Proposed Rule 2018

On Thursday, July 12, the Centers for Medicare & Medicaid Services (CMS) released the “Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program” Proposed Rule (Proposed Rule).

As you know, the American Ambulance Association worked closely with the Congress to ensure passage of the Bipartisan Budget Act of 2018 (BBA) (Pub. L. 115-123, enacted on February 9, 2018). The BBA not only extended the ambulance add-ons for 5 years, but also authorized a cost collection system that would not be overly burdensome on ambulance providers and suppliers, but would provide sufficient information ideally to support the permanent extension of the add-ons and set the basis for new payment models, including alternative destinations, treatment/assessment without transport, and community paramedicine.

After passage of the BBA, the AAA engaged immediate with CMS to ensure the smooth implementation of these provisions. Those contacts resulted in guidance earlier this year implementing the add-ons retroactively to January 1, 2019.

Consistent with the statute and already-released guidance, the Proposed Rule extends the three add-ons: the 2 percent urban, 3 percent rural, and 22.6 percent super-rural add-ons.  The Proposed Rule would codify the extension of the add-ons through December 31, 2022.

The Proposed Rule would implement the increase in the reduction in rates for non-emergency ambulance transports to/from dialysis facilities for services furnished on or after October 1, 2018. The 10 percent reduction applies for these transports furnished during the period beginning on October 1, 2013 and ending on September 30, 2018. The reduction will increase to 23 percent to conform the regulations to the statutory requirement for services furnished on or after October 1, 2018.

CMS does not request any information about the cost collection system in the Proposed Rule, but has been soliciting comments and recommendations through informal provider/supplier calls.  Additionally, the AAA has been in regular contact with CMS on the structure, design, and data elements to ensure the successful implementation of this critically important system as well.

Preliminary Estimate of 2018 Medicare Rates

A Preliminary Estimate of 2018 Medicare Rates

In this blog, I will provide a preliminary estimate of the Ambulance Inflation Factor (AIF) for calendar year 2018.  The AIF is main factor that determines the increase (or decrease) in Medicare’s payment for ambulance services.

Calculating the 2018 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. For 2018, this means the 12-month period ending on June 30, 2017. Starting in calendar year 2011, the change in the CPI-U is 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 resulting AIF is then applied to the conversion factor used to calculate Medicare payments under the Ambulance Fee Schedule.

The formula used to calculate the change in the CPI-U is limited to positive increases. Therefore, even if the change in the CPI-U was negative over a 12-month period (a rarity in the post-war era), the change in the CPI-U cannot be negative. However, when the MFP reduction is applied, the statute does permit a negative AIF for any calendar year. That is precisely what occurred in 2016, where the change in the CPI-U was 0.1% and the MFP was 0.5%. As a result, the industry saw an overall reduction in its Medicare rates of 0.4%.

Based on current data, it is highly unlikely that the AIF will be negative in 2018. For the 12-month period ending in June 30, 2017, the Bureau of Labor Statistics (BLS) currently calculates the change in the CPI-U to be approximately 1.6%.

CMS has yet to release its estimate for the MFP in calendar year 2018. However, assuming CMS’ projections for the MFP are similar to last year’s projections, the 2018 MFP is likely to be in the 0.3% to 0.5% range.

Therefore, at this time, my best guess is that the 2018 Ambulance Inflation Factor will be a positive 1.1% to 1.3%.

Please note that this estimate assumes the Bureau of Labor Statistics does not subsequently revise its inflation estimates. Please note further that this projection is based on the MFP being similar to last year.  To the extent either of these numbers changes in the coming months (up or down), my estimate of the 2018 AIF would need to be adjusted accordingly. Ultimately, the 2018 AIF will be finalized by CMS by Transmittal, which typically occurs in the early part of the 4th quarter.

Impact on the Medicare Ambulance Fee Schedule

Assuming all other factors remained the same, calculating your 2018 Medicare rates would be a relatively simple exercise, i.e., you would simply add 1.1 to 1.3% to your 2017 rates. However, as part of its 2018 Physician Fee Schedule Proposed Rule (issued July 21, 2017), CMS proposed minor changes to the GPCIs. These changes can be viewed by going to the Physician Fee Schedule page on the CMS website, and clicking the link for the “CY 2018 PFS Proposed Rule Addenda” (located in the Downloads section). You would then need to open the file for “Addendum E_Geographic Practice Cost Indicies (GPCIs).”

If the PE GPCI in your area is proposed to increase, you can expect your 2018 Medicare rates to increase by slightly more than 1.1 – 1.3%. If the PE GPCI in your area is proposed to decrease, you can expect your 2018 Medicare rates to increase by slightly less than 1.1 to 1.3%.

If you are looking for a more precise calculation of your rates, you will need to use the following formulas:

Ground Ambulance Services

Medicare Allowable = (UBR x .7 x GPCI) + (UBR x .3)

 Air Ambulance Services

Medicare Allowable = (UBR x .5 x GPCI) + (UBR x .5)

 In this formula, the “UBR” stands for the unadjusted base rate for each HCPCS code. These are calculated by multiplying the national conversation factor by the relative value unit assigned to each base rate. To save some time, estimates for the 2018 unadjusted base rates are reproduced below (using the low-end estimate for the AIF):

Base Rate (HCPCS Code) 2018 Unadjusted Base Rate
BLS non-Emergency (A0428) $224.74
BLS emergency (A0429) $359.58
ALS non-emergency (A0426) $269.68
ALS emergency (A0427) $427.00
ALS-2 (A0433) $618.02
Specialty Care Transport (A0434) $730.39
Paramedic Intercept (A0432) $393.29
Fixed Wing (A0430) $3,049.69
Rotary Wing (A0431) $3,545.72

Plugging these UBRs into the above formulas will result in adjusted base rates for each level of ground and air ambulance service. The final step is to apply whatever temporary adjustments are in effect under the Medicare Ambulance Fee Schedule. For example, in 2017, there were adjustments in place for urban (2%), rural (3%) and super-rural (22.6% over the corresponding rural rate) transports. Note: these temporary adjustments are currently set to expire on December 31, 2017. Therefore, absent further legislation, they should not be added to the adjusted base rates for 2018.

2018 Projected Rates for Mileage:

 At this time, I am estimating the following rates for Medicare mileage:

Base Rate (HCPCS Code) 2018 Unadjusted Base Rate
Ground Mileage – Urban $7.23
Ground Mileage – Rural Miles 1 – 17 $10.84
Ground Mileage – Rural Miles 18+ $7.23
Fixed Wing Mileage – Urban $86.5
Fixed Wing Mileage – Rural $12.98
Rotary Wing Mileage – Urban $23.09
Rotary Wing Mileage – Rural $34.64

Please keep in mind that a number of assumptions went into these projections. The Bureau of Labor Statistics can revise its inflation figures in the coming months. CMS may announce an MFP projection that differs from what we expect. CMS may also announce that it is electing not to finalize its proposed changes to the GPCI (highly unlikely). If any of these assumptions was to change, these projections would need to be revised. Therefore, I would suggest that you view these as rough estimates at best.  The AAA will update members as more information becomes available in the coming months.

Have an issue you would like to see discussed in a future Talking Medicare blog? Please write to me at bwerfel@aol.com.

 

 

 

CMS Issues Proposed Rule for Calendar Year 2016

On July 8, 2015, the Centers for Medicare and Medicaid Services (CMS) published a display copy of a proposed rule titled “Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016”.  The proposed rule makes a number of changes to the Medicare Physician Fee Schedule.  It also makes certain changes to the Medicare Ambulance Fee Schedule.  These proposed changes are summarized below.

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