Since the inception of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the Centers for Medicare and Medicaid Services (CMS) has been taking broad strokes to optimize the quality and cost of care delivery in the United States. While their efforts initially focused on physician office- and hospital-based patient care, the latest legislation takes aim at the Emergency Medical Services (EMS) industry.
In early 2018, the Bipartisan Budget Act of 2018 was officially signed into law and with it a new requirement for collecting cost and other financial data from ambulance service suppliers and providers, as outlined in section 50203(b). While this data collection is reflective of the payment reform initiatives for which the American Ambulance Association (AAA) has been advocating, the new policy is not without risks. Under the cost data collection initiative, financial data – including revenue, utilization, and expense (cost) data – will be collected via surveys, pulling from a subset of large and small ambulance services each year. Starting in 2020 and spanning the subsequent four years, the aggregate cost data will be used to develop a national benchmark against which all agencies will be measured moving forward.
While the objective is to create an ambulance fee schedule that better reflects the true costs of providing ambulance services, under the cost data collection program, municipal agencies will be compared to for-profit agencies, who often have more efficient operations and higher economies of scale. Without access to comprehensive cost data, smaller agencies will be at a disadvantage.
The Goal: A Fee Schedule That Accurately Reflects Holistic Patient Care
Current reimbursement rates reflect the cost of patient transport, but often discount the costs associated with delivering holistic patient care to the patient during his or her transport. While Medicare add-ons provide some relief, they are temporary and are therefore not sustainable. Unfortunately, there is currently little transparency into the costs and utilization trends across various equipment types, ground services, and geographic locations. By collecting a comprehensive set of cost data, CMS hopes to gain a deeper understanding of the costs associated with providing comprehensive patient services, enabling them to develop a reimbursement rate that reflects holistic patient care delivery.
The AAA has provided, and continues to provide, educational webinars and events, resource materials and YouTube videos that serve as an excellent reference on the history and the need for this data. If you’re wondering how best to get started, the following four questions can serve as a roadmap to evaluate whether your agency’s infrastructure, staff resources and operational processes will enable your long-term success.
Ambulance Cost Data Collection: The Top Four Questions to Validate Your Agency’s Readiness
1. Do you have the means to efficiently collect and report out all the data required of ground ambulance providers and/or suppliers?
For some EMS suppliers and providers, parsing through the necessary data elements may require resource-intensive, manual work. In addition to ensuring all the necessary cost data elements are documented and reported, agencies must ensure that costs not related to providing patient care and services – such as meals, personal vehicle use, entertainment, donations, etc. – are taken out as these are not permitted.
While the final framework is pending, required data elements may include, but are not limited to, the following:
- Ambulance services by level (e.g., ALS, BLS, etc.)
- Subscription and membership programs
- Medicare, Medicaid and other plans (e.g., commercial, private pay, VA, etc.)
- State and/or local subsidies
- Uncompensated care
- Dispatch, billing, and/or education and training services
- Salaries, wages and benefits
- Vehicle costs including insurance and maintenance
- Medical supplies
- Facilities and utilities
- Licensing and fees
- Billing services
2. How soon will you be prepared to report costs?
A new set of ambulance providers and suppliers will be selected by the CMS each year, identified by National Provider Identifier (NPI). While a provider with a higher number of NPIs has a higher likelihood of selection, agencies will be selected at random which means you may be required to report cost data to CMS as early as 2020. Will you be ready?
3. Is your organization categorized accurately?
CMS will use 855B enrollment form information to select and categorize providers. Unfortunately, the data contained within the 855B enrollment form is limited, making it difficult for CMS to make an apples-to-apples comparison between providers based on size and provider type. Have you confirmed that your 855B has been completed properly? Log in to the Provider Enrollment, Chain, and Ownership System (PECOS) website to validate your organization is categorized accurately.
4. Will your existing accounting and billing software support comprehensive and accurate cost data collection?
As previously mentioned, inaccurate data or costs not related to patient care must be corrected and/or removed from your cost data prior to reporting. Efficient and accurate reporting will necessitate billing software that allows you to tease out the required revenue data as well as accounting software that offers a chart of accounts with the necessary levels of detail. For example, if your accounting data shows a single line item for fuel, you may want to consider breaking that out by ambulance fuel versus fuel used for wheelchairs and other services.
The Time to Get Started Is Now
Effective January 1, 2022, selected ground ambulance providers and suppliers that fail to provide the required data will be subject to a 10% reduction in their Medicare payments! In short, failure to provide the required cost data will have long-lasting, negative impacts on your agency’s financial success.
Integra Connect’s cloud-based technology solutions can support your cost data collection initiatives.
Integra Connect has helped EMS organizations across the United States become more adaptable to industry changes by delivering technology-enabled capabilities that go well beyond the scope of traditional emergency medical billing. Our propriety billing system, including our reporting and analytics tools, was purpose-built to optimize the Revenue Cycle Management (RCM) process, maximizing our clients’ financial and operational success.
Our expert team is comprised of industry veterans each with more than twenty years of experience and, as the industry leader in Revenue Cycle Management, we have the people, processes and products to deliver exceptional results for our clients. To learn more about how our business intelligence, operational improvement, and enrollment consulting services can help your organization thrive, visit our website https://www.integraconnect.com/ems.