Medicare Changes Proposed- Part II- Cost Data Collection Explained

2020 Proposed Rule

Medicare Changes Proposed Part II

Welcome to Part II of our blog series featuring the proposed changes to Part B Payment Policies and revisions to Payment Policies under the Physician Fee Schedule. It’s been three weeks since CMS (Centers for Medicare and Medicaid Services) released the proposed rule and at this time we are in the middle of the comment period which lasts through September 27th.

If no changes are adopted, the rule will be published in November and the changes in the proposed rule will take effect on January 1, 2020.

Our Next Discussion

The last time we shared this blog space, we took a look at the changes that are proposed for the Physician Certification Statement (PCS) requirements. We discussed that instead of replacing the PCS rule, CMS decided to alter the rule, adding a non-physician statement and widening the list of healthcare providers who can sign-off on a document describing the medical necessity of the transport of this patient such that Medicare will pay for the resulting claim.

Today, our discussion will change direction to look at the new Medicare Ambulance Cost Data Collection mandate and how ambulance services will be required to provide cost data once every four years or face a monetary penalty of 10% less Medicare reimbursement for non-compliance. Agencies will file a separate cost data report for each individual National Provider Identifier (NPI) that is maintained by the agency providing ambulance service which is also an agency that bills Medicare for reimbursement of the costs of the services provided.

Why Cost Data Collection?

When Congress took action in 2018 to extend the Medicare Add-On Payments, the measure carried a mandate that requires CMS to collect cost data for ground ambulance. It is the intention of Congress to review the data collected by CMS in order to determine the ambulance industry’s profit and loss margins. Congress has stated that they will analyze the data resulting from the cost data collection initiative to attempt to “fix” the Medicare National Ambulance Fee Schedule with a new formula to permanently bridge the payment gap now patched over by the add-on payments (2% urban, 3% rural, 22.6% super rural and additional mileage payment in rural and super rural areas.)

Web-Based Tool

The cost reporting tool chosen by CMS is an online, web-based tool. The format has been released by CMS and a PDF version is available on the CMS website for review. Using the online method, CMS will set out to fulfill the Congressional mandate by collecting the total costs, total revenue figures and total utilization data.

The tool is designed to assist the responding ambulance services in breaking out non-ambulance related costs related but no directly associated with the ambulance of itself.

CMS explains that the ambulance services must take steps to properly separate out peripheral costs such as public safety costs, fire suppression costs (for fire-based EMS organizations) and hospital functions for facility-based agencies. CMS referred to these costs as “interwoven” costs and made a point in their release and subsequent explanations of the proposed rule how important it will be for an EMS agency to extract pure ambulance costs from other costs.

It also must be noted that this cost data collection exercise is intended for ground ambulance costs, only.

The web-based tool will prompt the respondent to separate out sub-categories such as…

  • Administrative staff not directly assigned to the ground ambulance program
  • Health care delivery outside of the ambulance
  • Community Paramedicine/Mobile Integrated Healthcare
  • Fire, police and/or other safety response costs

The reporting tool will also prompt the reporting agency to segment and identify partial EMS costs, such as an EMT that is also a firefighter. CMS claims that the tool will contain a formula and provide the opportunity for the respondent to allocate fire costs broken out of EMS costs

Next Time…

That’s all the information we have room for right now. But, be sure to check out our next blog in the series as we dive into the individual reporting categories and provide a thumbnail sketch of the individual data that will be required to be reported.

You won’t want to miss it!

Also…be sure to checkout our QMC EMS Board & Collar podcast series for those of you that don’t have a lot of time to read, but can listen to the podcasts while you’re on the go! You’ll find the podcast on all the major podcast platforms…simply search for “EMS Board & Collar”!

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