The growing EMS economic crisis is a combination of expense increases for service delivery AND the reimbursement for services provided.
One of the major factors in the revenue gap for EMS as a safety-net healthcare provider is the percentage of patients who cannot pay for their EMS care due to lack of insurance, meaning the patient is responsible for reimbursing the cost of EMS care.
To help NAEMT, AIMHI, and other associations develop communication strategies regarding public policy to address rising levels of uncompensated care, we are asking EMS agencies to help quantify the level of uncompensated care in their agency.
You can participate in the FLASH POLL through the on-line link here:
For your planning purposes, we’re including the questions on the poll below, so you know in advance what the questions are…
The Centers for Medicare and Medicaid Services (CMS) defines uncompensated care as “Health care or services provided by hospitals or health care providers that don’t get reimbursed. Often uncompensated care arises when people don’t have insurance and cannot afford to pay the cost of care.”
On March 9, 2024, the Centers for Medicare and Medicaid Services (CMS) announced the creation of the Change Healthcare/Optum Payment Disruption (CHOPD) Program. Under the CHOPD Program, CMS will make accelerated payments to Part A providers and advance payments to Part B suppliers that have experienced claims disruptions as a result of the Change Healthcare cyberattack.
Under the CHOPD Program, qualifying providers and suppliers will be eligible to apply for and receive Medicare advances of up to 30 days of their average Medicare payments. Applications for payment advances must be made to the provider’s or supplier’s Medicare Administrative Contractor (MAC). The 30-day payment advance will be based on the average Medicare payments to the provider or supplier between August 1, 2023 and October 31, 2023. Specifically, CMS will compute the total amounts paid to the provider during this period, and then divide by 3 to arrive at the 30-day average amount.
Advance payments received through the CHOPD Program are considered a loan. Therefore, these amounts must be repaid through offsets against future Medicare payments. Recoupments will commence on the date the advance payments are received by the provider or supplier. These recoupments will be equal to 100% of future payments, and will continue until the earlier to occur of: (1) the full repayment of the advance payment or (2) 90 days. In the event a balance remains after 90 days, the MAC will generate a demand notice for the outstanding balance, which must be repaid within 30 days. If the provider does not repay the outstanding balance within that period, interest will start to accrue on the outstanding balance.
Providers and suppliers with multiple National Provider Identifiers (NPIs) may be eligible for multiple advance payments.
Eligibility Requirements
To qualify for advance payments, a provider or supplier must meet the following requirements:
Advance payments may be requested for individual providers or suppliers, i.e., a unique NPIs and Medicare ID (PTAN) combination.
The provider or supplier must not currently be receiving Periodic Interim Payments.
The provider or supplier must make the following certifications:
The provider/supplier must certify that they have experienced a disruption in claims payment or submission due to a business relationship the provider/supplier has with Change Healthcare or another entity that uses Change Healthcare, or the provider’s/supplier’s third-party payers have with Change Healthcare or another entity that uses Change Healthcare.
The provider/supplier must not be able to submit claims to receive claims payments from Medicare.
The provider/supplier has been unable to obtain sufficient funding from other available sources to cover the disruption in claims payment, processing, or submission attributable to the cyberattack
The provider/supplier does not intend to cease business operations and is presently not insolvent.
The provider/supplier, if currently in bankruptcy, will alert CMS about this status and include case information.
Based on its information, knowledge and belief, the provider/supplier is not aware that the provider/supplier or a parent, subsidiary, or related entity of the provider/supplier is under an active healthcare-related program integrity investigation in which the provider/supplier or a parent, subsidiary, or related entity of the provider/supplier: (1) is under investigation for potential False Claims Act violations related to a federal healthcare program; (2) is a defendant in state or federal civil or criminal action (including a qui tam False Claims Act action either filed by the Department of Justice or in which the Department of Justice has intervened; or (3) has been notified by a state or federal agency that it is a subject of a civil or criminal investigation or Medicare program integrity administrative action; or (3) has been notified that it is the subject of a program integrity investigation by a licensed health insurance issuer’s special investigative unit.
The provider/supplier is enrolled in the Medicare program had has not been revoked, deactivated, precluded, or excluded by CMS or the HHS Office of the Inspector General.
The provider/supplier does not have any delinquent Medicare debts.
The provider/supplier is not on a Medicare payment hold or payment suspension.
The provider/supplier will use the funds for the operations of the specific provider/supplier for which they were requested.
To the extent a provider or supplier is approved for an advance payment, they must then execute a Terms and Conditions document acknowledging the following:
That the funds were advanced from the Medicare Trust Fund, and represent an advance on claims payments.
The accelerated and advance payment is not a loan, and cannot be forgiven, indebtedness cannot be reduced, and there are no flexibilities regarding repayment timelines. CMSI will use its standard recoupment procedures to recover these amounts.
Repayment will commence immediately via 100% recoupment of Medicare claims payment owed to the provider/supplier, as the provider/supplier submits claims and claims are processed, after the date on which the payment is granted. Recoupment will continue for a period of 90 days.
A demand will be issued for any remaining balance on Day 91 following the issuance of the advance payment.
Interest will start to accrue 30 days after a demand is issued consistent with the interest rate established under applicable interest authorities.
CMS will proceed directly to demand the advance payments if any certifications or acknowledgements are found to be falsified.
Grant of an advance payment is not guaranteed and payments will not be issued once the disruption to claims servicing is remediated, regardless of when a request is received. CMS may terminate the program at any time.
CMS maintains the right to conduct post payment audits related to any advance payments issued under this program.
The Centers for Medicare & Medicaid Services (CMS) is continuing to monitor and assess the impact that the cyberattack on UnitedHealth Group’s subsidiary Change Healthcare has had on all provider and supplier types. Today, CMS is announcing that, in addition to considering applications for accelerated payments for Medicare Part A providers, we will also be considering applications for advance payments for Part B suppliers.
Over the last few days, we have continued to meet with health plans, providers and suppliers to hear about their most pressing concerns. As announced previously, we have directed our Medicare Administrative Contractors (MACs) to expedite actions needed for providers and suppliers to change the clearinghouse they use and to accept paper claims if providers need to use that method. We will continue to respond to provider and supplier inquiries regarding MAC processes.
CMS also recognizes that many Medicaid providers are deeply affected by the impact of the cyberattack. We are continuing to work closely with States and are urging Medicaid managed care plans to make prospective payments to impacted providers, as well.
All MACs will provide public information on how to submit a request for a Medicare accelerated or advance payment on their websites as early as today, Saturday, March 9.
CMS looks forward to continuing to support the provider community during this difficult situation. All affected providers should reach out to health plans and other payers for assistance with the disruption. CMS has encouraged Medicare Advantage (MA) organizations to offer advance funding to providers affected by this cyberattack. The rules governing CMS’s payments to MA organizations and Part D sponsors remain unchanged. Please note that nothing in this statement speaks to the arrangements between MA organizations or Part D sponsors and their contracted providers or facilities.
The Ambulance Open Door Forum (ODF) addresses issues related to the Medicare payment, billing, and coverage for air and ground ambulance services. The Ambulance Fee Schedule (AFS) proposed and final rules, rural and other additional payments under the AFS, and Prior Authorization of Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) are just some of the many types of issues addressed within the forum. In addition, discussions differentiating the rules related to ambulance providers and independent ambulance suppliers are facilitated. Timely announcements and clarifications regarding important rulemaking, agency program initiatives and other related areas are also included in the forum.
The Centers for Medicare & Medicaid Services (CMS) released a new “Reporting for Rural and Super-Rural Organizations Tip Sheet” on February 16, 2024. This guide assists ground ambulance organizations in rural and super-rural areas to meet the Medicare Ground Ambulance Data Collection System (GADCS) requirements.
You can find all of their tip sheets, including those focused on allocation, governmental, and public safety organizations, on the CMS GADCS website.
Services selected as part of the Year 3 and Year 4 list are due to submit their 2023 data to CMS by May 31, 2024, or 5 months after the close of their fiscal year. The AAA offers various resources to help services collect, verify, and submit data on time and avoid penalties. For more information about our resources, including Amber, email hello@ambulance.org.
Starting January 1, 2024, selected ground ambulance organizations in Year 3 and Year 4 are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10 percent payment reduction.
Learn about an updated user guide and upcoming webinar:
Medicare Ground Ambulance Data Collection System: Updated GADCS User Guide
Do you have questions about the Medicare Ground Ambulance Data Collection System (GADCS)? CMS and our contractors will address GADCS-related questions in real-time. While everyone is welcome to participate, this session will be most relevant to selected ground ambulance organizations in Year 3 and Year 4 of the GADCS as they begin reporting data to CMS in 2024.
This session will be divided into 2 topics:
2–2:30pm: GADCS instructions and how to respond to specific questions
2:30–3pm: User accounts, accessing the GADCS portal, and information technology issues
Starting January 1, 2024, selected ground ambulance organizations in Year 3 and Year 4 are required to report cost, utilization, revenue, and other information to CMS. Organizations that fail to report may be subject to a 10 percent payment reduction.
Medicare Ground Ambulance Data Collection System Overview Webinar – January 18
Thursday, January 18 from 2– 3:30 pm ET
Register for this webinar. While everyone is welcome to participate, this session will be most relevant to selected ground ambulance organizations in Years 3 and 4 as they start reporting Medicare Ground Ambulance Data Collection System (GADCS) data to CMS in 2024.
This 60-minute presentation will cover all aspects of the GADCS, including:
Overview and key concepts
Section walkthrough
User accounts, logging in, and linking to your organization
Submitting and certifying your data
A Q&A session will follow the presentation.
More Information:
Ambulance Events webpage: The January 18 presentation will be posted here
Recorded November 2023
Outside the US Capitol during 2023 Stars of Life, Prodigy’s Rob Lawrence caught up with American Ambulance Association Immediate Past President Shawn Baird. Shawn shared next steps following the last meeting of the Ground Ambulance Patient and Billing Advisory Committee.
