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Author: AAA Staff

CMS Announces Ambulance Services Selected for Year 2 Data Collection

The Centers for Medicare and Medicaid Services (CMS) has announced the names of those ground ambulance service providers and suppliers who will be required to submit their data for year 2 under the ambulance data collection system. To see the list of providers and suppliers selected for year 2, please go to the Ambulances Services Center page of the CMS website and scroll down to “Ground Ambulance Providers and Suppliers Selected to Submit Data in Year 2 (Zip)” or click here to download the file directly.

Those providers and suppliers selected for either year 2 or year 1 will need to capture and report their data for a 12-month period beginning between January 1, 2022 and December 31, 2022. Providers and suppliers will have 5 months from the end of their reporting period in which to submit their data to CMS. CMS delayed the capturing and reporting of ambulance data due to the COVID-19 public health emergency.

Request FREE Amber Access

The future of EMS hinges on the CMS Ground Ambulance Cost Data Collection process. Amber, a cost collection tool, helps EMS agencies collect and verify their cost collection data before submitting it to CMS.

Sponsored by The Savvik Foundation, the American Ambulance Association is providing FREE access to Amber for all EMS services, regardless of type and size.

Along with Amber access services will receive a 1-year AAA membership, including all Ambulance Cost Education materials, access to the AAA’s cost collection experts, the AAA Accounting Manual, and all other member benefits.

In order to be approved for the grant, you must commit to reporting your data into our AMBER software. 

Apply Now>

CMS Releases Proposed Cost Collection Rule

CMS has released the proposed rule that would establish the ambulance fee schedule cost collection system as required by statute.

The proposed rule sets the foundation for the data collection system for ground ambulances.  It proposes a stratified random sample method, that is very similar to the one the AAA proposed via the work we commissioned through The Moran Company. We are working through the stratification categories, which are slightly different than those we identified.

CMS also proposes the cost and revenue data elements it plans to use.  There are some details in the proposed rule text and others will be in the proposed tool that will be posted the CMS website today.

CMS also proposes the collection period and penalties for failing to report.

While the data collection provision was the key component for ground ambulance services, CMS also proposed changes to the PCS requirement sought by the AAA. CMS is proposing to reference the PCS also as non-physician certification agreements. The agency is further proposing to clarify that the focus is on the certification of the medical necessity provisions and the form of the certification statement is not prescribed.  As part of the non-physician statement, CMS is proposing expanding the staff of you may sign the statement when an attending physician is unable to sign.

AAA Members Can Download Full PDF Summary by Kathy Lester, Esq.

Read the Proposed Rule

Questions?: Contact Us:

If you have questions about the legislation or regulatory initiatives being undertaken by the AAA, please do not hesitate to contact a member of the AAA Government Affairs Team.

Tristan North – Senior Vice President of Government Affairs | (202) 802-9025

Aidan Camas – Manager of State & Federal Government Affairs | (202) 802-9026

Thank you for your continued membership and support.

How Hard Could Cost Data Collection Be Anyway?

Cost Data Collection…how hard could it really be?  You have costs, you report costs, job complete…right?


We wish it would be that simple, but the fact is cost data collection is more involved, and many ambulance services do things slightly (or not so slightly) differently which makes this process even more difficult.  Ambulance services across the country need to get on the same page so we are able to submit data that makes sense, paints a clear picture of what it costs to do what we do, and allows policy makers to make informed decisions that will actually benefit mobile healthcare.

The proposed rule was released by CMS on Monday, July 29th and the AAA’s summary of the rule is available for members here.  The proposed rule, for the most part, aligns with the recommendations of the AAA.  As we continue to learn exactly how cost data collection will look in terms of reporting elements and collection process, and the ACE Faculty is continuously updating content and webinars so services across the country can be prepared for this process when it begins on January 1, 2020.

For more information on ambulance cost data collection and all the American Ambulance Association is doing to help services across the country prepare, visit  You will find both free resources and paid subscriptions are available to fit your budget and help your service prepare for the future of EMS.


Volunteer Labor: Understanding the True Cost of Doing Business

There are three parts to ever story – a beginning, a middle, and an end. Likewise, there are three parts to running an ambulance service (humor me here); clinical staff (beginning) patients (middle) and administrators (end). This comparison is over-simplified, but the point is this – whether you are a 5-person volunteer service or a 5-state ambulance service, it takes the same basic things to operate. When it comes to cost data collection and ensuring organizations like CMS understand the true cost of doing business, we need to make sure we are sharing our individual stories in the same way.

Full-Time ambulance services can likely report the cost of doing business relatively easily. They can run reports on the number of FTEs they have, how much they’re spending in overtime, equipment costs, and so on. Volunteer organizations have a slightly different story. When some hear about an organization that runs on volunteer labor, they mistakenly connect the word volunteer to free or cheap. The true story is that many costs go into operating a volunteer service, and a volunteer workforce is anything but free or cheap. Understanding how to calculate the true cost of volunteer labor is a critical skill for those charged with running a service that utilizes volunteers in isolation or as part of a mixed workforce.

On February 6th, the American Ambulance Association is hosting an Ambulance Cost Data Collection webinar on the topic of volunteer labor and how to calculate the cost of a volunteer workforce.

Some of the items Scott Moore Esq., HR and Operations consultant for the AAA, will review in the webinar are:

• EMS industry volunteer organizational and labor statistics in the United States
• National statistics for calculating the value of volunteer labor
• Methodologies and formulas other Medicare reimbursed healthcare providers must furnish as part of their industry Medicare Cost Reports
• How EMS agency’s use and percentage of volunteer labor has historically impacted GAO reports and reimbursement rates
• Key cost related factors that will be required to report labor costs for volunteers accurately
• The importance of tracking the hours of all volunteers by position.
• Which costs you should include when calculating the cost of volunteer labor and those commonly missed

Calculating the cost of volunteer labor is undoubtedly one of the more difficult, and most important, components of the cost data collection process. This webinar will leave you with a standard formula you can use to calculate the cost of volunteer labor within your service. If you are leading a volunteer organization, you need to participate in this webinar along with the individual or team that looks after your finances.

Looking for more ambulance cost data collection content? Visit You will find both free resources and paid subscriptions are available to fit your budget and help your service prepare for the future of EMS.

Request for Proposals—SME/Project Director

American Ambulance Association
Request for Proposals
SME/ Project Director
Ambulance Cost Data Collection
November 2018


The American Ambulance Association (AAA) invites proposals from qualified interested parties (individual and teams) for the purpose of directing the Ambulance Cost Data Project as a Subject Matter Expert (SME).


As part of the extension of the Ambulance Medicare Add on payments, legislation passed on February 9, 2018, the Congress mandated that ambulance services provide cost data.  General requirements of the legislation include the following:

  • Requires notice-and-comment rulemaking
  • May use a cost survey
  • Collect (1) cost; (2) revenue; (3) utilization; and (4) other information determined appropriate by the Secretary
  • Include information: (1) needed to evaluate the extent to which costs are related to payment rates; (2) on the utilization of capital equipment and ambulance capacity; and (3) on different types of ground ambulance services furnished in different geographic locations and low population density areas
  • May revise the system over time
  • Select a representative sample of providers and suppliers from whom to collect data
  • Determined based on the type of providers and suppliers and the geographic locations
  • May not be request same provider or supplier to submit data in two consecutive years
  • A selected to report must do so in the form and manner and at the time specified by the Secretary
  • If a selected and do not report, then may be subject to a 10 percent payment reduction, unless the hardship exemption
  • Opportunity to request a review of the application of the penalty
  • Information collected available through the CMS Website

AAA Cost Data Collection Objectives

The purpose of the AAA Cost Data Collection is to develop education and service lines to assist the industry in preparing to accurately respond to the federally mandated cost data collection system as designed by the Centers for Medicare and Medicaid Services (CMS). Objectives to include:

  1. Standardization of the education of the cost data collection system including standardization of terms.
  2. The development of a cost data app to be universally distributed and used by ambulance services to report costs.
  3. AAA’s cost data recommendations are considered the industry standard and tools are widely distributed and used by the majority stakeholders of the industry.
  4. Initial (beta) data used to analyze and validate cost collection system, and provide data needed to continue lobbying Congress on additional reimbursement payments.

Proposed Project Director (SME) Scope of Work

In order to achieve the above objectives, the following is the proposed director (SME) scope of work:

  • Review and comment on AAA Cost Data Collection deliverables, including publications, education efforts, and online tools, helping to maximize accessibility and utility while verifying accuracy.
  • In partnership with the Technology and Education contractor, provide industry and ambulance service support, both reactively in answering questions and proactively in presentations both remotely and in person.
  • In collaboration with the AAA Cost Data Collection Faculty, contribute and edit content for the data collection operational definitions.
  • Update website, write articles, member communications and information pieces for distribution and website posting.
  • Working with the Technology and Education contractor, monitor and support the receipt of initial data, reviewing to identify missing fields and outliers; follow-up and clean data as needed.
  • Using data generated by the data collection system, generate articles and reports reflecting analysis and synthesis.
  • As requested, prepare reports and provide counsel to the AAA Board throughout the term of the project.

Proposed Project Timeline

December, 2018 — Board Consideration of AAA Cost Data Collection Proposal and Budget Request

January 1, 2019 — Hire SME

January–February 2019 — Development of operational definitions

March–April 2019 — Review and finalization of operational definitions

Summer 2019 — Review of Amber online toolset, support of pilot testing

September-December — Ongoing education – including train the trainer materials and final pre-launch education

Throughout 2019 — Ongoing educational and awareness-raising work, development and enhancement of website content

Instructions for Submission of Responses

Please include the following information in your Response.

  • Cover letter indicating cost for providing services as outlines in the RFP.
  • Resume and/or Curriculum Vitae (CV)
  • A list of three references (including phone numbers), as well as a brief description of the project for the reference
  • Any samples you wish to use to showcase your work as a project director and/or SME

Submit the above materials to Maria Bianchi electronically at

We would appreciate a response to the proposal no later than Friday, December 7, 2018.

If you have any questions, contact Maria Bianchi at 301-758-2927.

Statement on Cost Data Collection for Ambulance Services

For Immediate Release
Contact: Amanda Riordan
Phone: 703-615-4492

WASHINGTON, DC—On October 17, the International Association of Fire Chiefs (IAFC), International Association of Fire Fighters (IAFF), and The Metropolitan Fire Chiefs Association released a joint statement discouraging fire-based providers from endorsing AAA’s proposed ambulance cost collection methodology. While we regret to learn that they do not believe that our method is appropriate for the segment of providers they represent, we respectfully disagree and invite open dialogue as our previous requests to discuss cost collection with the IAFF and IAFC were declined.

The American Ambulance Association membership is composed of ambulance providers of all types and sizes, ranging from non-profit, for-profit, volunteer, hospital-based, county-based, public utility models, and more. We represent 911 ambulance providers in major metropolitan areas, small 911 providers in rural America, and those who provide vital hospital-to-hospital interfacility mobile healthcare throughout the country. AAA encourages all ambulance providers to visit to learn about the extensive research, time, and thought devoted to ensure that our comprehensive recommendations accurately capture data for the full spectrum of providers.

“Regardless of an ambulance organization’s service model, we collectively serve our communities with round-the-clock mobile healthcare. The collection and analysis of accurate cost data for ambulance providers of all types is essential to the future of our industry. If adopted by CMS, AAA’s cost collection recommendations will demonstrate the value of the care that we provide to our patients, as well as open the door for the establishment of forward-thinking payment models that sustain operations and grow innovation. The American Ambulance Association welcomes discussion with fire and other stakeholders. Our door is always open,” said AAA President Aarron Reinert on Monday.

Medicare cost reporting is an exhaustive and extremely technical system that has been in place in other healthcare specialties for many years. While not all ambulance services are Medicare “providers of service,” it has long been clear to AAA that ambulance services would eventually be required to provide cost data to support Medicare reimbursement, especially for purposes of making the add-ons permanent and expanding the benefit to include innovative payment models, including mobile integrated health. As such, our ambulance cost collection leadership began in 2012 with the commission of an extensive independent research study to design a cost model that would be accurate, complete, and minimally burdensome to ambulance providers of all sizes, types, and models. The findings of this study were released in 2014 and form the foundation of AAA’s cost data collection system design.

Following extensive advocacy efforts led by the American Ambulance Association, the Bipartisan Budget Act of 2018 was passed into law in February of this year. This bill included language that extended the ambulance Medicare add-ons for five years. It also required that ambulance services begin collecting and reporting cost data to the Centers for Medicare & Medicaid Services (CMS) in 2020. CMS has the ability to determine certain aspects of how the data is collected as well as the data elements so AAA is working closely with this agency to advocate for the implementation of our survey-based model. It is also clear that given the Congressional instruction to use the cost collection data to assess Medicare rates, the data collection will be aligned with the costs Medicare has the statutory authority to reimburse, but not necessarily all costs suppliers may incur to support the non-healthcare aspects of their services.

It is essential that ambulance providers speak with one voice on this critically important issue.  Inconsistencies in reporting and failure to standardize costs allowable under the Medicare statute will result in data being eliminated and will threaten the sustainability of the program. As such, throughout this lengthy and intensive process, AAA leadership remains open to feedback and focused on the development of and advocacy for a cost collection system that encompasses all mobile healthcare provider types. Learn more at


About the American Ambulance Association (AAA)

The AAA was formed in 1979 in response to the need for improvements in emergency medical services and mobile healthcare. The American Ambulance Association represents hundreds of ambulance services across the United States who provide emergency and interfacility mobile healthcare. The Association serves as a voice and clearinghouse for ambulance services.

50% of EMS Services Submit Data in: -415 Days 18 Hours 19 Minutes 2 Seconds