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7/27 CMS Ambulance Open Door Forum

Written by AAA Staff on . Posted in Regulatory.

From CMS on July 19, 2023

CMS Open Door Forum

The next CMS Ambulance Open Door Forum scheduled for:

Date:  Thursday, July 27, 2023

Start Time:  2:00pm-3:00pm PM Eastern Time (ET);

Please dial-in at least 15 minutes before call start time.

Conference Leaders: Jill Darling, Maria Durham 

**This Agenda is Subject to Change**

  1. Opening Remarks

Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing

Moderator – Jill Darling (Office of Communications)

Announcements & Updates

  1. Ground Ambulance & Patient Billing Advisory Committee Meeting Announcement
  2. Update on Emergency Triage, Treat, and Transport (ET3) Model
  3. Medicare Ground Ambulance Data Collection System (GADCS): Proposed Changes in the CY 2024 Physician Fee Schedule Proposed Rule
    1. Slide presentation will be available at: https://www.cms.gov/medicare/ambulance-fee-schedule-zip-code-files/ambulance-events
  4. Consolidated Appropriations Act, 2023:  Division FF, section 4103: Extension of Add-On Payments for Ambulance Services

III. Open Q&A

**DATE IS SUBJECT TO CHANGE**

Next Ambulance Open Door Forum: TBA

ODF email: AMBULANCEODF@cms.hhs.gov

———————————————————————

This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.

NEW and UPDATED Open Door Forum Participation Instructions:

This call will be a Zoom webinar with registration and login instructions below.

Register in advance for this webinar:

https://cms.zoomgov.com/webinar/register/WN_Sq7TP07ESqiGuvE0M00xIg

Webinar ID: 161 099 7532

Passcode: 131371

After registering, you will receive a confirmation email containing information about joining the webinar. You may also add the webinar to your calendar using the drop-down arrow on the “Webinar Registration Approved” webpage after registering. Although the ODFs are now a Zoom webinar, we will only use the audio function, no need for cameras to be on.

For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/OpenDoorForums/.

Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. The webinar recording and transcript will be posted to: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.

CMS Open Door Forum Footer

3/16 | CMS Ambulance Open Door Forum

Written by Amanda Riordan on . Posted in Regulatory.

The next CMS Ambulance Open Door Forum scheduled for:

Thursday, March 16, 2023
2:00pm-3:00pm PM Eastern Time (ET);

This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849

Conference Leaders: Jill Darling, Maria Durham

**This Agenda is Subject to Change**
I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing
Moderator – Jill Darling (Office of Communications)

II. Announcements & Updates
• Medicare Ground Ambulance Data Collection System
(GADCS): Top 5 Tips for Selected Organizations in Year 1, 2, 3, and 4
Slide presentation will be available on CMS’ Ambulances
Services Center website: https://www.cms.gov/medicare/ambulance-fee-schedule-zipcode-files/ambulance-events
Please see the following information regarding COVID-19
PHE Updated Guidance for Ambulance Organizations:
Public Health Emergency (PHE) 1135 Waivers: Updated
Guidance for Providers

III. Open Q&A
**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov

———————————————————————
This Open Door Forum is open to everyone, but if you are a member of the Press,
you may listen in but please refrain from asking questions during the Q & A portion of
the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank
you.

Open Door Participation Instructions:
This call will be Conference Call Only.
To participate by phone:
Dial: 1-888-455-1397 & Reference Conference Passcode: 4325849

Persons participating by phone do not need to RSVP. TTY Communications Relay
Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-
800-855-2880. A Relay Communications Assistant will help.
Instant Replay: 1-800-814-6745; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
800-814-6745 and entering the Conference Passcode beginning 1 hours after the call
has ended. The recording is available until March 18, 2023, 11:59PM ET.
For ODF schedule updates and E-Mailing List registration, visit our website at
http://www.cms.gov/OpenDoorForums/.
Were you unable to attend the recent Ambulance ODF call? We encourage you to
visit our CMS Podcasts and Transcript webpage where you can listen and view the
most recent Ambulance ODF call. The audio and transcript will be posted to:
https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.
CMS provides free auxiliary aids and services including information in accessible
formats. Click here for more information. This will point partners to our CMS.gov
version of the “Accessibility & Nondiscrimination notice” page. Thank you.

CMS Ambulance Open Door Forum Summary

Written by Brian Werfel on . Posted in Cost Data Collection, Medicaid, Medicare, Member Advisories.

On August 18, 2022, the Centers for Medicare and Medicaid Services (CMS) held its most recent Ambulance Open Door Forum (ODF). As is typically the case, CMS started the ODF with a series of announcements, before opening the call to questions from the ambulance industry.

 

The first announcement related to proposed changes to the regulations governing the medical necessity requirements for non-emergency, scheduled, repetitive ground ambulance services. Specifically, CMS is proposing to modify the so-called “special rule” for repetitive, scheduled non-emergency services (set forth in the regulations at 42 C.F.R. §410.40(e)(2)(ii)). CMS indicated that these proposed changes would provide necessary and ensure the consistent application of the documentation requirements by its contractors. The proposed change would add language indicating that both the Physician Certification Statement and “additional documentation from the beneficiary’s medical record” could be used to support medical necessity for the ambulance transport. The new language would further indicate that these documents must provide detailed explanations that are consistent with the beneficiary’s current medical condition. On the ODF, CMS encouraged the industry to submit comments on these proposed changes. However, CMS indicated that, because these changes were the subject of ongoing rulemaking, it would not be able to answer any questions on the ODF.

 

The second announcement related to the proposed changes to the Medicare Ground Ambulance Data Collection System (GADCS) included in the July 2022 Proposed Rule. CMS and its contractor, the Rand Corporation, went through a detailed PowerPoint presentation that summarized these proposed changes. That PowerPoint presentation can be accessed by clicking here.

 

As part of its discussion of the GADCS, CMS also announced the implementation of an automated process for requesting hardship exemptions and informal review of determinations that an ambulance provider is subject to a financial penalty for failing to properly submit its cost data.

 

The final announcement related to ambulance services furnished by Rural Emergency Hospitals (REHS). In the FY 2023 Outpatient Hospital Proposed Rule, CMS is proposing to codify in its regulations the statutory requirement that ambulance services furnished by entities that are owned and operated by REHS will be paid under the Medicare Ambulance Fee Schedule. CMS is also proposing to revise the origin and destination requirements to include REHS as both a covered origin and covered destination for ambulance services.

 

The ODF concluded with a brief Q&A period. All of the questions posed to CMS related to the GADCS.  One of the questions placed to CMS was whether it would permit ambulance suppliers to prospectively seek a hardship exemption, i.e., to permit an ambulance supplier to ask now that it be relieved of the financial penalties for failing to report its cost data. The person posing the question specifically referenced ambulance suppliers impacted by the severe flooding in the State of Kentucky. CMS confirmed that an ambulance supplier had to be notified that it was subject to a financial penalty before it was eligible to seek a hardship exemption.

CMS Ambulance Open Door Forum scheduled for Thursday, August 18

Written by Amanda Riordan on . Posted in Regulatory.

CMS Open Door Forum
The next CMS Ambulance Open Door Forum scheduled for:

Date:  Thursday, August 18, 2022

Start Time:  2:00pm-3:00pm PM Eastern Time (ET);

Please dial-in at least 15 minutes before call start time.

Conference Leaders: Jill Darling, Maria Durham

**This Agenda is Subject to Change**

  1. Opening Remarks

Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing

Moderator – Jill Darling (Office of Communications)

  1. Announcements & Updates
  1. Medicare Ground Ambulance Data Collection System: Proposed Changes in the CY 2023 Physician Fee Schedule (PFS) Proposed Rule

Slide presentation is available at: https://www.cms.gov/Center/Provider-Type/Ambulances-Services-Center, under Spotlights, Upcoming Events

2. CY 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical  Center (ASC) Payment System Proposed Rule: https://www.federalregister.gov/documents/2022/07/26/2022-15372/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment

Proposals Regarding Rural Emergency Hospitals Ambulance Services

III. Open Q&A

**DATE IS SUBJECT TO CHANGE**

Next Ambulance Open Door Forum: TBA

ODF email: AMBULANCEODF@cms.hhs.gov

———————————————————————

This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.

Open Door Participation Instructions:

This call will be Conference Call Only.

To participate by phone:

Dial: 1-888-455-1397 & Reference Conference Passcode: 5109694

Persons participating by phone do not need to RSVP. TTY Communications Relay Services are available for the Hearing Impaired.  For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.

Instant Replay: 1- 866-469-7806; Conference Passcode: No Passcode needed

Instant Replay is an audio recording of this call that can be accessed by dialing 1-866-469-7806 and entering the Conference Passcode beginning 1 hours after the call has ended. The recording is available until August 20, 2022, 11:59PM ET.

For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/OpenDoorForums/.

Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. The audio and transcript will be posted to: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.

TODAY | CCIIO Open Door Forum No Surprises Act

Written by AAA Staff on . Posted in Finance, Legislative, Regulatory.

Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight

Special Open Door Forum: Provider Requirements under the No Surprises Act
Wednesday December 8, 2021 | 2:00-3:00 pm Eastern Time
Conference Call Only
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468

 

The Center for Consumer Information and Insurance Oversight (CCIIO) and the CMS Office of Communication will host an orientation to provider requirements under the No Surprises Act.

Starting January 1, 2022, consumers will have new billing protections when getting emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers. Through new rules aimed to protect consumers, excessive out-of-pocket costs will be restricted, and emergency services must continue to be covered without any prior authorization, and regardless of whether or not a provider or facility is in-network.

On July 1, 2021, the “Requirements Related to Surprise Billing; Part I,” interim final rule was issued to restrict surprise billing for patients in job-based and individual health plans who get emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers.

On September 30, 2021, a second interim final rule was issued and is open for public comment. The “Requirements Related to Surprise Billing; Part II” rule provides additional protections against surprise medical bills, including:

  • Establishing an independent dispute resolution process to determine out-of-network payment amounts between providers (including air ambulance providers) or facilities and health plans.
  • Requiring good-faith estimates of medical items or services for uninsured (or self-paying) individuals.
  • Establishing a patient-provider dispute resolution process for uninsured (or self-paying) individuals to determine payment amounts due to a provider or facility under certain circumstances.
  • Providing a way to appeal certain health plan decisions.

Together, these lay the groundwork to provide consumers with protection against surprise billing, starting in 2022. Learn more about how these rules help consumers.

Here is the link to our No Surprises page that has the slides: https://www.cms.gov/nosurprises/Policies-and-Resources/Provider-requirements-and-resources

We look forward to your participation.

Special Open Door Participation Instructions:

Participant Dial-In Number: 1-888-455-1397

Conference ID #: 8604468

Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help. 

A transcript and audio recording of this Special ODF will be posted to the Podcast and Transcripts website at https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html for downloading.

For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at http://www.cms.gov/OpenDoorForums/.

Thank you for your interest in CMS Open Door Forums.

CMS | Ambulance Open Door Forum Dec 9

Written by AAA Staff on . Posted in ET3, Regulatory.

The next CMS Ambulance Open Door Forum scheduled for:

Date:  Thursday, December 9, 2021

Start Time:  2:00pm-3:00pm PM Eastern Time (ET);

Please dial-in at least 15 minutes before call start time.

To participate by phone:

Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468

Conference Leaders: Jill Darling, Maria Durham

**This Agenda is Subject to Change**

  1. Opening Remarks

Chair- Maria Durham, Director, Division of Data Analysis and Market Based Pricing

Moderator – Jill Darling (Office of Communications)

Announcements & Updates

  1. Emergency Triage, Treat, and Transport (ET3) Model Update
  2. Upcoming Implementation Dates of the Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model
  3. Ground Ambulance & Patient Billing Advisory Committee Member Nomination Period
  1. CY 2022 Ambulance Inflation Factor (AIF) Change Request 12488, Transmittal 11044
  2. Medicare Ground Ambulance Data Collection System CY 2022 Physician Fee Schedule Final Rule

III. Open Q&A

**DATE IS SUBJECT TO CHANGE**

Next Ambulance Open Door Forum: TBA

ODF email: AMBULANCEODF@cms.hhs.gov

———————————————————————

This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.

Open Door Participation Instructions:

This call will be Conference Call Only.

To participate by phone:

Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468

Persons participating by phone do not need to RSVP. TTY Communications Relay Services are available for the Hearing Impaired.  For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.

Instant Replay: 1-800-856-2271; Conference Passcode: No Passcode needed

Instant Replay is an audio recording of this call that can be accessed by dialing 1-800-856-2271 and entering the Conference Passcode beginning 1 hours after the call has ended. The recording is available until December 11, 2021, 11:59PM ET.

For ODF schedule updates and E-Mailing List registration, visit our website at http://www.cms.gov/OpenDoorForums/.

Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. Please allow up to three weeks to get both the audio and transcript posted to: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

CMS provides free auxiliary aids and services including information in accessible formats. Click here for more information. This will point partners to our CMS.gov version of the “Accessibility & Nondiscrimination notice” page. Thank you.

CCIIO Open Door Forum No Surprises Act

Written by AAA Staff on . Posted in Finance, Legislative, Regulatory.

From CMS on December 3, 2021

Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight

Special Open Door Forum: Provider Requirements under the No Surprises Act
Wednesday December 8, 2021 | 2:00-3:00 pm Eastern Time
Conference Call Only
Participant Dial-In Number: 1-888-455-1397
Conference ID #: 8604468

 

The Center for Consumer Information and Insurance Oversight (CCIIO) and the CMS Office of Communication will host an orientation to provider requirements under the No Surprises Act.

Starting January 1, 2022, consumers will have new billing protections when getting emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers. Through new rules aimed to protect consumers, excessive out-of-pocket costs will be restricted, and emergency services must continue to be covered without any prior authorization, and regardless of whether or not a provider or facility is in-network.

On July 1, 2021, the “Requirements Related to Surprise Billing; Part I,” interim final rule was issued to restrict surprise billing for patients in job-based and individual health plans who get emergency care, non-emergency care from out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers.

On September 30, 2021, a second interim final rule was issued and is open for public comment. The “Requirements Related to Surprise Billing; Part II” rule provides additional protections against surprise medical bills, including:

  • Establishing an independent dispute resolution process to determine out-of-network payment amounts between providers (including air ambulance providers) or facilities and health plans.
  • Requiring good-faith estimates of medical items or services for uninsured (or self-paying) individuals.
  • Establishing a patient-provider dispute resolution process for uninsured (or self-paying) individuals to determine payment amounts due to a provider or facility under certain circumstances.
  • Providing a way to appeal certain health plan decisions.

Together, these lay the groundwork to provide consumers with protection against surprise billing, starting in 2022. Learn more about how these rules help consumers.

Here is the link to our No Surprises page that has the slides: https://www.cms.gov/nosurprises/Policies-and-Resources/Provider-requirements-and-resources

We look forward to your participation.

Special Open Door Participation Instructions:

Participant Dial-In Number: 1-888-455-1397

Conference ID #: 8604468

Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help. 

A transcript and audio recording of this Special ODF will be posted to the Podcast and Transcripts website at https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.html for downloading.

For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at http://www.cms.gov/OpenDoorForums/.

Thank you for your interest in CMS Open Door Forums.

CMS | Open Door Forum on Prior Authorization for RSNAT

Written by Amanda Riordan on . Posted in Regulatory.

From CMS on October 5, 2021

Centers for Medicare & Medicaid Services Center for Medicare and Medicaid Innovation

Special Open Door Forum:  Repetitive, Scheduled Non-Emergent Ambulance Transport Prior Authorization Model National Expansion

Thursday, October 28, 2021
2:00-3:30 pm Eastern Time
Conference Call Only

Participant Dial-In Number: 1-888-455-1397 | Conference ID #: 8604468

CMS will host a Special Open Door Forum (SODF) to allow ambulance suppliers, other Medicare providers, and additional interested parties to learn about the upcoming national expansion of the Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) Prior Authorization Model in Medicare fee for service. CMS is implementing the national model in multiple phases beginning with Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, and Texas on December 1, 2021.  The RSNAT Prior Authorization Model is currently operating in New Jersey, Pennsylvania, and South Carolina since 2014 and in North Carolina, Virginia, West Virginia, Maryland, Delaware, and the District of Columbia since 2016. This Special ODF will include information on national expansion, the prior authorization process, and a Q&A period.

You can find more information on the model and slides for the ODF presentation by going to:

http://go.cms.gov/PAAmbulance

Questions on the model can be sent to: AmbulancePA@cms.hhs.gov

We look forward to your participation.

Special Open Door Participation Instructions:

Participant Dial-In Number: 1-888-455-1397

Conference ID #: 8604468

Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.

A transcript and audio recording of this Special ODF will be posted to the Special Open Door Forum website at https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts for downloading.                  

For automatic emails of Open Door Forum schedule updates (E-Mailing list subscriptions) and to view Frequently Asked Questions please visit our website at https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums

Thank you for your interest in CMS Open Door Forums.

CMS Open Door Forum | Medicare Ground Ambulance Data Collection System

Written by AAA Staff on . Posted in Cost Data Collection, Cost Survey, Regulatory.

August 12, 2021 Ambulance Open Door Forum

August 12, 2021 | 14:00–15:30 ET

Slide presentation on the Overview of the Medicare Ground Ambulance Data Collection System (PDF) is now available.

The next CMS Ambulance Open Door Forum scheduled for:
Date: Thursday, August 12, 2021
Start Time: 2:00pm-3:30pm PM Eastern Time (ET);
Please dial-in at least 15 minutes before call start time.
Conference Leaders: Jill Darling, Maria Durham

Agenda

**This Agenda is Subject to Change**

I. Opening Remarks
Chair- Maria Durham, Director, Division of Data Analysis and Market-based Pricing
Moderator – Jill Darling (Office of Communications)

II. Announcements & Updates

  • Emergency Triage, Treat, and Transport (ET3) Model Update
    • ET3 Model Website: https://innovation.cms.gov/innovation-models/et3
      • ET3Model@cms.hhs.gov for inquiries
      • ET3 Model Listserv for Model updates: https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_12521

 

Overview of the Medicare Ground Ambulance Data Collection
System
 A copy of the presentation will be available on the
Ambulances Services Center website under
Spotlights: https://www.cms.gov/Center/ProviderType/Ambulances-Services-Center
III. Open Q&A

**DATE IS SUBJECT TO CHANGE**
Next Ambulance Open Door Forum: TBA
ODF email: AMBULANCEODF@cms.hhs.gov
———————————————————————
This Open Door Forum is open to everyone, but if you are a member of the Press, you may listen in but please refrain from asking questions during the Q & A portion of the call. If you have inquiries, please contact CMS at Press@cms.hhs.gov. Thank you.

Open Door Participation Instructions

This call will be Conference Call Only.

To participate by phone:
August 12, 2021 | 14:00–15:30 ET | Dial: 1-888-455-1397 & Reference Conference Passcode: 8604468
Persons participating by phone do not need to RSVP. TTY Communications Relay
Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880. A Relay Communications Assistant will help.

Instant Replay

1-866-470-7051; Conference Passcode: No Passcode needed
Instant Replay is an audio recording of this call that can be accessed by dialing 1-
866-470-7051 and entering the Conference Passcode beginning 1 hours after the
call has ended. The recording is available until August 14, 2021, 11:59PM ET.

For ODF schedule updates and E-Mailing List registration, visit our website at
http://www.cms.gov/OpenDoorForums/.

Were you unable to attend the recent Ambulance ODF call? We encourage you to visit our CMS Podcasts and Transcript webpage where you can listen and view the most recent Ambulance ODF call. Please allow up to three weeks to get both the
audio and transcript posted to: https://www.cms.gov/Outreach-andEducation/Outreach/OpenDoorForums/PodcastAndTranscripts.html.

 

Summary of March 28, 2019 Ambulance ODF

Written by Brian Werfel on . Posted in Finance, Medicare, Member-Only, News, Reimbursement.

The Centers for Medicare and Medicaid Services (CMS) held its latest Open Door Forum on Wednesday, March 28, 2019.  As with past Open Door Forums, CMS started the call with the following announcements:

  1. Ambulance Cost Data Collection – CMS reminded the industry that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, requires CMS to create a new cost data collection system by December 31, 2019.
  2. Emergency Triage, Treat, and Transport Model – A representative from the Innovation Center within CMS provided an overview of the “Emergency Triage, Treat, and Transport Model” or “ET3.” This is a 5-year pilot program intended to provide ambulance providers with greater flexibility to handle low-acuity 911 calls, by providing Medicare payment for: (a) ambulance transportation to alternative treatment destinations and (b) treatment at the scene. The CMS representative indicated that CMS is in possession of data that suggests that 16% of emergency ambulance transports to a hospital emergency department could have been resolved by transporting the patient to an alternative treatment site, e.g., an urgent care center. CMS estimates that had all of these patients elected to receive care in the lower-acuity setting, it would have saved the Medicare Program approximately $560 million each year. With respect to the operation of the model itself, CMS essentially repeated the information that had been previously provided on its webinars. You can view the AAA Member Advisory on the ET3 Model by clicking here.
  3. Ambulance Inflation Factor – CMS reiterated that the 2019 Ambulance Inflation Factor is 2.3%.

Following the announcements, CMS moved into a Question & Answer period. The majority of the questions related to the ET3 pilot program. As is typical, many questions were not answered on the call; instead, CMS asked the individual to submit their question in writing. However, the following questions were answered on the call:

  1. Payment Rates under ET3 – CMS was asked whether the BLS base rate payment would be the BLS emergency base rate. It was not clear that the CMS representative fully understood the question, although she indicated that it would.
  2. Eligibility for Government Agencies – CMS was asked whether governmental agencies that operate 911 centers would submit applications to participate as part of the RFA process in the Summer of 2019. CMS responded that governmental agencies that operate 911 centers would not submit RFAs, but would rather wait for the Notice of Funding Opportunity (NOFO), which will be issued after the ambulance providers and suppliers are selected for participation (expected to be the late Fall/Winter of 2019). CMS further confirmed that if the governmental agency also operated its own ambulance service that it would be eligible to apply for both aspects of the ET3 Model.
  3. Limit on Ambulance Providers – CMS was asked whether it would cap the number of ambulance providers and suppliers selected to participate in the program. CMS responded that, at the present time, it has no intent to cap the number of participating ambulance providers and suppliers at any specific number.
  4. Return Transports from Alternative Treatment Destinations – CMS was asked whether the model would provide for ambulance payment for the return transport after a patient was transported to an alternative treatment site. CMS indicated that the model does not provide for payment for the return transport.
  5. Definition of “Telehealth” – CMS confirmed that the model will use the same definition of “telehealth” used in other areas of the Medicare Program. CMS further confirmed that telehealth encounters require both audio and video connections.
  6. Approval of Alternative Treatment Sites – CMS confirmed that state and local regulatory agencies would have final approval over acceptable alternative treatment sites.
  7. Qualified Health Care Practitioner – CMS confirmed that a “qualified health care practitioner” would be an individually enrolled Medicare practitioner, which includes physicians and nurse practitioners. In some instances, it can also include physician’s assistants. CMS confirmed that the definition would not include registered nurses or advance scope paramedics.
  8. NOFO Funding – CMS indicated that, at the present time, it is not prepared to release additional details on the nature or size of the funding opportunities available to governmental agencies and their designees that operate or have authority over 911 centers.
  9. Medicare Advantage and Other Payers – CMS confirmed that the ET3 Model applies only to Medicare beneficiaries enrolled in FFS Medicare. It does not apply to Medicare Advantage enrollees, Medicaid recipients, etc.

Questions? Email Brian at bwerfel@aol.com

CMS Non-Emergency Ambulance Transport Open Door Forum 7/26

Written by Kathy Lester on . Posted in Medicare, Member Advisories, Member-Only, News, Regulatory.

CMS Issues Data Elements and Templates for Non-Emergency Ambulance Transports (NEAT): Open Door Forum for
Thursday, July 26, 2018 Just Announced

As part of its Patients Over Paperwork Project, the Centers for Medicare & Medicaid Services (CMS) Provider Compliance Group (PCG) has been hosting quarterly listening sessions and reviewing the Request for Information submissions. The American Ambulance Association has been actively engaged in these efforts, highlighting the recommendations we submitted to CMS and the House Ways & Means Committee last year. These recommendations included suggestions as to how CMS could streamline regulatory requirements to eliminate duplicative requirements and reduce regulatory burdens.  In addition to these efforts, CMS has been working to standardize documentation data elements and establish templates that providers and suppliers can use to help make the current documentation processes less burdensome as well.

On July 24, CMS released draft documentation-related clinical data elements and clinical templates that could be used for the Physician Certification Statement, Progress Notes, and Prior Authorization requests. View the Documents. These documents are not intended to change current law.

CMS also announced yesterday that it will discuss the templates on a Special Open Door Forum which is scheduled for July 26 at 2-3 pm ET.  The call-in information is:

  • Participant Dial-In Number: 1-(888)-989-4575
  • Conference ID: 3068545

We have shared our concern about the short notice about the call and CMS has indicated it will continue to take comments on the documents after the call as well. The AAA is in the process of reviewing these documents closely and will develop a written comment letter to provide to CMS after the call on Thursday. We welcome input from all our members as part of this process.

While these new documents may be helpful for many services, the AAA also remains committed to move its recommendations which would result in some changes in the PCS and other ambulance provider and supplier requirements.

 

 

Summary of March 2018 Ambulance Open Door Forum

Written by Brian Werfel on . Posted in Medicare, Member-Only, News, Reimbursement.

CMS held its latest Open Door Forum on Wednesday, March 7, 2018. As with past Open Door Forums, CMS started the call with the following series of announcements:

Medicare Fee Schedule – CMS indicated that the Bipartisan Budget Act of 2018, enacted on February 9, 2018, contained several provisions that impacted the payment of ambulance claims under the Medicare Ambulance Fee Schedule:

  • Temporary Add-Ons for Ground Ambulance – CMS indicated that Section 50203(a) of the bill extended the temporary add-ons for ground ambulance services for an additional five years, retroactive back to January 1, 2018.  As extended, these add-ons will expire on December 31, 2022.  These add-ons increase Medicare’s allowable for ground ambulance base rates and mileage by 2% in urban areas, 3% in rural areas, and by 22.6% (over the applicable rural rate) for services provided in so-called “super rural” areas.
  • Cost Reporting – CMS indicated that Section 50203(b) of the bill would require ground ambulance providers and suppliers to submit cost data to CMS. CMS noted that the new law requires CMS to develop, no later than December 31, 2019, a data collection system to collect cost, revenue, utilization, and certain other information related to ground ambulance services. The law provides that cost data will be collected using a survey methodology, with a representative sample of ambulance providers and suppliers being asked to submit cost data in any given year.  Finally, CMS noted that, starting on January 1, 2022, providers or suppliers that fail to submit the requested cost data would be subject to a 10% reduction in their Medicare payments, unless otherwise exempted on the basis of significant hardship.
  • Additional Reduction in Medicare Payment for Dialysis Transports – Section 53108 of the bill provides that the Medicare allowable for non-emergency, basic life support transports to and from dialysis will be subject to a further 13% reduction.  This reduction would go into effect for dialysis transports with dates of service on or after October 1, 2018. This would be on top of the existing 10% reduction in Medicare’s payment for dialysis transports, for a total reduction of 23%.

Temporary Enrollment Moratorium – CMS indicated that the temporary moratorium on the enrollment of new ground non-emergency ambulance providers in Texas was lifted on September 1, 2017. CMS further indicated that the enrollment moratorium was extended for the states of New Jersey and Pennsylvania for an additional six months on January 29, 2018. CMS will need to make a determination on or before July 29, 2018 on whether to lift the moratorium or extent it for an additional six months in that state.

Following the announcements, CMS moved into a brief Question & Answer period.  Most of the questions were not answered on the call; instead, CMS took the contact information of the person asking the question, and indicated that they would respond directly to them at a later date.  However, the following questions were answered:

  1. CMS indicated that a Change Request had been sent to all Medicare Administrative Contractors (MACs) informing them of the new, adjusted fee schedule amounts. CMS further indicated that this Change Request, which it indicated was confidential, provided further instructions to the MACs on when and how to adjust claims initially paid at the original 2018 rates.
  1. CMS confirmed that the adjusted rates are retroactive to January 1, 2018. Accordingly, CMS indicated that claims paid at the original 2018 rates will be adjusted by the MACs at some future date.
  1. CMS indicated that it recently released its First Interim Evaluation Report on the Medicare Prior Authorization Model for repetitive, non-emergency ground ambulance transports. CMS further indicated that it was still reviewing this report, and that no decision has yet been made on the extension of this model within the existing 9 states and the District of Columbia and/or the expansion of the model to additional states.

Have questions? Please write to the Werfels at bwerfel@aol.com.

Summary of December 2017 Ambulance Open Door Forum

Written by Brian Werfel on . Posted in Medicare, Member-Only, News, Reimbursement.

On December 14, 2017, CMS held its latest Open Door Forum. As usual, it started with a few announcements, as follows:

  1. Ambulance Inflation Factor – CMS announced that it had published Transmittal 3893 on October 27, 2017, which sets forth the Ambulance Inflation Factor (AIF) for calendar year 2018. In that Transmittal, CMS indicated that the CY 2018 AIF would be 1.1%. This is based on an increase in the CPI-U of 1.6%, and a multi-factor productivity adjustment of 0.5%.
  1. Expiration of Temporary Adjustments – CMS indicated that the current temporary adjustments for urban (2%), rural (3%) and super rural ground ambulance transports are set to expire on December 31, 2017. CMS also indicated that they were aware of proposed legislation that would extend these adjustments for 2018 and beyond, but that they have yet to be enacted into law.
  1. CY 2018 Public Use File – CMS indicated that the Public Use File on its website has been updated to include Medicare allowables for 2018. CMS made a point of noting that the 2018 rates do not include the temporary adjustments, as they are set to expire on December 31, 2017.
  1. Prior Authorization Demonstration Project – CMS indicated that it had decided to extend the Prior Authorization Demonstration Project for schedule, non-emergency ground ambulance transportation of repetitive patients for another year. The extension is limited to the 8 states (DE, MD, NJ, NC, PA, SC, VA, and WV) and the District of Columbia in which the program was in effect in 2017.  CMS further indicated that the extension would be effective for dates of service on or after December 5, 2018.  As a result, claims for dates of service between December 2 and December 4 would not be subject to prepayment review if a prior authorization was not received; however, ambulance providers in these states would be permitted to request prior authorization for those dates. CMS further indicated that it had developed a “streamlined” process to allow for prior authorization of transports in situations where the patient was approved for transport, but where the duration of the authorization was shortened from the normal 60-day period to account for the program’s scheduled expiration on December 1, 2017. An example would be an authorization that was granted for transports starting on November 1, 2017. The provider was likely given authorization for only a 30-day period. The streamlined process would allow them to submit a request to allow that 30-day authorization to be extended to a fully 60 days. CMS indicated that the streamlined process would not require the submission of medical records to establish medical necessity for the ambulance.

As with previous forums, CMS then fielded questions from the audience. The majority of these questions focused on the prior authorization process. As with previous ODFs, CMS declined to answer most of the questions on the call, instead asking the provider to submit their questions to CMS via email.

CMS did answer the following questions on the call:

  1. CMS was asked when it anticipated issuing its report on the effectiveness of the Prior Authorization Demonstration Program.  CMS responded that it expected to issue that report during the first quarter of 2018.
  2. CMS was asked when it expected to expand the Prior Authorization Demonstration Program to additional states and/or the nation as a whole.  CMS responded that it was still evaluating the effectiveness of the program.  Therefore, CMS indicated that no decision on national expansion had been made at this time.

Have questions? Please write to the Werfels at bwerfel@aol.com.

Summary of September 2017 Ambulance Open Door Forum

Written by David Werfel on . Posted in Medicare, Member-Only, News, Reimbursement.

On September 14, 2017, CMS held its latest Open Door Forum. As usual, it started with a few announcements, as follows:

  1. “Locality” Rule – On 6/16/17 CMS issued Transmittal 236, to amend the Benefit Policy Manual, Chapter 10, section 10.3.5 to give Medicare Administrative Contractors discretion to determine the “locality”. This is for the issue of the nearest appropriate facility.

Transmittal 236

  1. ALS Assessment – The same Transmittal also amended section 30.1.1 to indicate that if an ALS assessment is performed, then the ALS emergency base rate shall be paid, even if there is no ALS intervention.
  2. Multiple Patient Transports – On 9/1/17, CMS issued Transmittal 3855 to restore to its Claims Processing Manual, Chapter 15, section 30.1.2 instructions for multiple patients transported in the same vehicle. This is not a change in policy. The section was inadvertently omitted from the Internet Only Manual.

Transmittal 3855

  1. Temporary Adjustments – The 2%, 3% and 22.6% temporary adjustments for ground ambulance transports originating in urban, rural and super-rural areas will expire 12/31/17, unless legislation is enacted. Later on the call, they indicated that they are aware of a legislative initiative in Congress that includes this issue (S.967, H.R. 3236).

Support Extending the Medicare Add-ons!

       Following these announcements, a Q & A period ensued. Most of the questions were not answered on the call, other than to advise the caller to submit their question via e-mail and CMS will respond to their concern via e-mail or to contact their Medicare Administrative Contractor.

Two items of note in the Q & A were as follows:

  • CMS has left it up to the MACs to define the “locality” for purposes of the nearest appropriate facility requirement. Therefore, providers and suppliers should ask their MAC for their definition.
  • CMS was asked whether the prior authorization program would continue nationwide, after this year. The representatives from CMS did not answer the question other than to advise the person who asked the question to submit it in writing to CMS.

Have questions? Please write to the Werfels at bwerfel@aol.com.

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