Does your fire department bill for EMS service? If so, the Centers for Medicare and Medicaid Services (CMS) wants to get a snapshot of your agency’s EMS costs, revenues, and utilization. Providing this data to CMS on a timely and accurate basis will be crucial for efforts to reform the Medicare Ambulance Fee Schedule and improve the reimbursements that the federal government provides to fire and EMS agencies for caring for Medicare beneficiaries.
Last year, Congress passed legislation which provided a long-term extension of the Medicare Ambulance Add-On Payments, also known as the “ambulance extender” payments. These payments represent an additional 2%, 3%, and 22.6%, which are provided for transports originating in urban, rural, and super-rural zip codes. Securing an extension of the ambulance extender payments has always been a challenge and generally was only done in six to twelve-month increments. To secure this long-term extension, Congress mandated CMS to develop a data collection process in order to obtain “cost, revenue, and utilization data” from agencies that bill Medicare for EMS. Congress and the IAFC hope that this data will help evaluate CMS’ payments for EMS and potentially improving CMS’ reimbursement rates.
CMS released their long-awaited proposal for this data collection process in August. According to the proposal, CMS will conduct their data collection process from 2020 through 2024. All EMS agencies that bill Medicare for service will be required to report their data in one of these four years. CMS plans to utilize an online survey tool to gather data on an agency’s EMS costs, revenues, and utilization. The draft survey tool guides respondents through CMS’ required data fields and skips any data fields which are not relevant to a respondent (i.e., career agencies won’t need to answer questions about volunteer incentives).
The IAFC generally is supportive of CMS’ draft proposal. Earlier in this process, the IAFC worked with other national fire and EMS organizations to encourage CMS to adopt a data collection method similar to the one used by state Medicaid agencies when administering supplemental payment programs like the Ground Emergency Medical Transportation (GEMT) program. While CMS rejected outright adoption of all pre-existing data collection systems, including the Moran Study and the GEMT, CMS developed a cost collection system that mirrors many elements of the GEMT.
In September, the IAFC joined with the International Association of Fire Fighters to offer comments to CMS which generally address the following topics:
Fire Department Non-Transport Services
The IAFC encouraged CMS to collect information on the extent to which a transport agency relies upon a fire department or other EMS agency to provide an initial response, assessment, and patient care. The IAFC believes that non-fire based EMS agencies often receive significant benefit from EMS services that are provided by fire departments and should be required to report the extent to which they benefit from these services and this labor. Additionally, this information will be valuable in developing a more complete understanding of the amount of unreimbursed EMS services that fire departments provide.
Responses for Deceased Patients
Fire departments often provide extensive responses to patients who ultimately are declared as deceased on-scene. However, an agency’s protocols may require the administration of medications and aggressive procedures before pronouncing the patient as deceased. However, CMS’ reimbursements do not reflect these extensive efforts and significantly under-reimburse agencies. The IAFC encourages CMS to gather data on the costs that agencies incur in responding to deceased patients. The IAFC hopes this data will lead to more accurate reimbursements in cases where a patient is pronounced as deceased prior to transportation.
Improved Cost Definitions
CMS’ proposal contains directions for counting the number of hours that an agency’s personnel work in EMS and non-EMS capacities. In counting an individual’s number of EMS hours worked, CMS directs agencies to exclude hours dedicated to delivery patient care “unrelated to ground ambulance.” The IAFC believes this is vague and urges CMS to clarify that this means time spent on healthcare tasks in a clinical setting rather than pre-hospital EMS care provided by personnel assigned to non-transport vehicles such as an engine company or zone car.
CMS also wants to gain information on the value of services provided by volunteer EMS personnel. CMS proposes to require respondents to report only the number of hours work by volunteers and not to estimate a value of these hours. Instead, CMS plans to multiply these hours by the average wage data for EMS personnel, as reported by the U.S. Bureau of Labor Statistics (BLS). However, the IAFC encourages CMS to find an alternate valuation for volunteer hours since the BLS’ data only contains information on wages for firefighters and EMS personnel, but not cross-trained firefighter/paramedics and firefighter/EMTs. The IAFC fears that relying on the BLS’ incomplete data could lead to an underestimated valuation of the services provided by volunteer personnel.
CMS’ data collection process is an essential next step in developing the hard data needed to correct the Medicare Ambulance Fee Schedule. Without these data points, the fire and emergency service will be unable to demonstrate the enormous misalignment that exists between the costs of providing EMS care with the actual reimbursements provided to agencies.
It’s imperative that agencies selected to participate in this process do so as accurately and thoroughly as possible. The IAFC’s EMS Section plans to offer resources in the near future to assist agencies in better understanding this process as well as how to identify their EMS cost, revenue, and utilization data. Make sure to keep an eye out for these new resources so that you can be best prepared to help improve reimbursements for fire and EMS agencies across the nation.
Evan Davis is a strategic manager with government relations at the IAFC.