Dear Ground Ambulance Providers and Suppliers,
Starting January 1, 2023, ground ambulance organizations selected in  Year 1 and Year 2 are required to report cost, utilization, revenue, and other information to CMS within 5 months after your data collection period ends. Organizations that fail to report may be subject to a 10% payment reduction. Ground ambulance organizations selected in Year 3 and Year 4 will begin collecting data in 2023 and reporting data beginning in 2024.

Medicare Ground Ambulance Data Collection System: Office Hours Session — April 27
Thursday, April 27 from 2–3 pm ET
Register for this webinar.

We divided the office hours session into 2 topics:
2–2:30 pm: CMS will answer live questions on the data collection requirements (such as what am I required to collect and when do I report?).  This part of the session is for all selected organizations in Years 1–4.
2:30–3 pm: We’ll answer live questions about registering and requesting access to the Medicare Ground Ambulance Data Collection System portal. This part is for selected organizations in Years 1–2 who are required to report beginning in 2023.

Visit Medicare Ground Ambulance Data Collection System for:
Lists of ground ambulance organizations selected in Years 1–2 required to collect information starting in 2022 and report information starting in 2023
Organizations selected in Years 3–4 required to collect information starting in 2023 and report information starting in 2024
FAQs

Ambulance providers are most likely working on cost reporting or preparing to collect their data. Fifty percent (50%) of the EMS organizations have been collecting their ground ambulance cost data over the course of 2022 for reporting by May 2023. The other half of the EMS organizations are reviewing the newly released “Year 3” and “Year 4” lists to begin cost data collection in January 2023 for reporting by May 2024. This task is to comply with the new CMS Ground Ambulance Data Collection System.  For the last several years, the AAA and the ACE faculty have been performing workshops and webinars about these new cost collection requirements because the data collected will be used to reform the Medicare Fee Schedule and the way EMS organizations are reimbursed for years to come.

We want to highlight the steps EMS organizations should be taking today to facilitate the collection of accurate cost related data. Due to the way the Ambulance Cost Data Collection Instrument asks for certain information, you and your team must capture some data at the beginning of the collection period. It will be difficult, if not impossible, for organizations to retroactively capture this data.

1. Sign up for & log in to AMBER
   Knowing that there are significant differences amongst EMS organizations when it comes to the various processes and software platforms where cost data might be housed, the AAA decided to create a software platform specifically designed for the new Medicare Ground Ambulance Cost Data Collection System. AMBER is a web-based software built to model the CMS Cost Collection Tool and follows the same skip logic. EMS organizations can start and stop, go back, and adjust data; the tool includes an error checker that makes it easy to identify mistakes, or possible mistakes during data validation.AAA members already have access to Amber as part of their membership, but Amber is available to all EMS services regardless of AAA membership or service type. To log in or request free access, visit https://emsamber.com/.
2. Verify the Information in PECOS and with your MAC
   PECOS is the Provider Enrollment and Chain of Ownership System utilized by Medicare for provider enrollment and revalidation. It is important that the organization verifies all the data about their organization in PECOS, specifically the ownership, contact address, and managing employee information. You want to ensure CMS has the correct contact information in case they need to notify your organization relative to your cost data collection process. If your organization was selected but you have not been notified by your Medicare Administrative Contractor (MAC), it could be because your information is not up to date.If you were selected for data collection in 2022, you should have already received a notification from your MAC. This notification includes that your organization was selected and that you need to notify the MAC whether your organization will report on a calendar or fiscal year. Whether you have received this notification or not, you should contact your MAC to confirm this information and ensure that they have noted your collection year in their system. If you do not, the default designation is reporting on a calendar year. You will create additional work if this is not how your organization currently accounts for your financial data.

   If you have not been selected for data collection in 2022, you will be selected to collect your data in 2023.  The year 3 and 4 lists were published by CMS on November 7, 2022.  However, you should know that any EMS agency that billed Medicare for transports will be reporting their data this year or next year.

3. Create a Personnel Snapshot
   Section 7 of the Medicare Ground Ambulance Cost Data Collection Instrument seeks information about the labor costs at your EMS organization. Organizations will be providing the total compensation and hours for their employees by employee category.The Instrument asks organizations to report individuals based on the position they held at the start of the data collection period. If an employee progresses from an EMT to Paramedic during the course of the year, the instrument requires that the new paramedic’s hours and compensation be in the EMT category.

   There are a few possible ways that organizations can ensure that they report their labor costs consistent with the Instrument’s instructions. The easiest is to take a snapshot of the personnel roster at the beginning of the data collection year. This ensures that any employee who changes position during the year is tagged and reported appropriately. Many of the scheduling software platforms have an existing “other” identifier field in the administration setup for employees. Also, most payroll software platforms have canned reports in their reporting suite that identify employees with status changes during a particular period. Lastly, you can simply keep a list of any employee who, for reporting purposes, you need to go back and adjust your compensation and hour reporting to ensure you have accounted for their costs consistent with the Cost Collection Instrument.

4. Track Volunteer Time/Hours
   Also in Section 7 of the Instrument, organizations who utilize volunteer labor are required to report the number of hours their volunteers worked during the data collection period. Many EMS organizations that utilize volunteer labor do not currently track their volunteer’s time. The organization must establish a process for ensuring that they have a method for tracking the working hours of their volunteer employees during the reporting period. This can be done utilizing various software or manual processes. Whichever way your organization decides to track this information, it will be easier to start the data collection period with an established process.
5. Update/Modify Your Dispatch System & Processes
   The Cost Data Collection Instrument requires that the organization report their average trip time (in minutes) across all service levels (BLS, ALS, etc.) in your primary service area. This is calculated from the time the ambulance leaves the station to when that ambulance is available to take another call.To ensure that you are capturing data consistent with the Instrument’s definition of “average trip time,” organizations can either make adjustments to their dispatch software or simply ensure that your dispatchers/communications personnel are accounting for the time it takes your ambulance to return to their service area where the ambulance is “available to take another call.”  For many services transporting long distances to destinations outside their service area, the ambulance is not “available to respond to another call” when they clear the receiving facility. Failing to account for this time is truly not providing CMS with an accurate picture of the costs of providing ambulance services.
6. Snapshot of Vehicle Mileage
   Section 9 of the Cost Collection Instrument seeks the total number of miles the organization’s vehicles traveled over the course of the data collection period. The easiest way to get this information is to take a snapshot of the starting mileage on all vehicles (ambulance and non-ambulance) at the start of the data collection year. The agency can take another snapshot at the end of the data collection year. This will ensure that the total agency mileage can be captured for all vehicles for the data collection period.
7. Check Payor Categories
   Section 13 of the Instrument asks the EMS organization to report all revenues received by the organization, including those not related to the provision of ground ambulance services. The instrument requires that the organization report revenues in the following payor categories:

• • Medicare
  • Medicare Managed Care
  • Medicaid
  • Medicaid Managed Care
  • Tricare
  • Veterans Administration (VA)
  • Commercial Insurance
  • Worker’s Compensation
  • Patient Self-Pay

Many billing software platforms do not distinguish between a standard commercial payor and a worker’s compensation payor. It is important that organizations make modifications to the payor set-up in their billing platform to ensure that they can easily sort revenue information according to the required payor categories.

Conclusion

We have heard from several services that their NPI was not selected in any of the lists published by CMS.  We have reached out to CMS to get guidance for those services that would normally be selected based on their billing Medicare for ground ambulance services during the 2019 calendar year. We will keep members posted as soon as we hear back from CMS but we encourage those services to prepare as if they were selected.

The preceding seven steps are a few that we believe are critical to ensure that your organization can more easily and accurately collect and report your ground ambulance cost data. We believe that cost collection is an important step in our profession’s evolution. Cost Reporting will frame the reimbursement structure for years to come. Additionally, failing to report your data to CMS will result in a 10% penalty on all reimbursement from Medicare for a full calendar year.

The AAA has created numerous resources and tools to assist you and your team when preparing and completing the Cost Collection Instrument.  These can be found by visiting the Cost Collection section of the AAA website. Contact hello@ambulance.org if you have any questions or need assistance.

It is finally here. Fifty (50%) of the EMS organizations will begin collecting ground ambulance cost data in 2022 for reporting by May 2023. The other half of the EMS organizations will collect their data beginning in 2023 for reporting by May 2024. All of this, to comply with the new CMS Ground Ambulance Data Collection System.  For the last several years, the AAA and the ACE faculty have been performing workshops and webinars about these new cost collection requirements because the data collected will be used to reform the Medicare Fee Schedule and the way EMS organizations are reimbursed for years to come.

We wanted to highlight the steps that EMS organizations should be taking today to facilitate the collection of accurate cost-related data. Due to the way the Ambulance Cost Data Collection Instrument asks for certain information, it will be necessary for you and your team to capture some data at the beginning of the collection period. It will be difficult, if not impossible, for organizations to retroactively capture this data.

2. Access Amber
Knowing that there are significant differences amongst EMS organizations when it comes to the various processes and software platforms where cost data might be housed, the AAA decided to create a software platform specifically designed for the new Medicare Ground Ambulance Cost Data Collection System. Amber is a web-based software built to model the CMS Cost Collection Tool and follows the same skip-logic. EMS organizations can start and stop, go back, adjust, and validate your data before submitting it to CMS. The built-in error checker makes it easy to identify mistakes, or possible mistakes, and make corrections.

AAA members already have access to Amber as part of their membership, but Amber is available to all EMS services regardless of AAA membership or service type. To log in or request free access, visit https://emsamber.com/.

2. Verify the Information in PECOS
PECOS is the Provider Enrollment and Chain of Ownership System utilized by Medicare for provider enrollment and revalidation. It is important that the organization verify all the data about their organization in PECOS but specifically the ownership, contact address, and managing employee information. You want to ensure that CMS has the correct contact information in case they need to notify your organization relative to your cost data collection process. If your organization was selected but you have not been notified by your Medicare Administrative Contractor (MAC), it could be because your information is not up to date.

3. Contact Your Medicare Administrative Contractor (MAC)
If you were selected for data collection in 2022, you should have already received a notification from your MAC. This notification includes that your organization was selected and that you need to notify the MAC whether your organization will report on a calendar or fiscal year. Whether you have received this notification or not, you should contact your MAC to confirm this information and ensure that they have noted your collection year in their system. If you do not, the default designation is reporting on a calendar year. You will create additional work if this is not how your organization currently accounts for your financial data.

4. Snapshot of Personnel
Section 7 of the Medicare Ground Ambulance Cost Data Collection Instrument seeks information about the labor costs at your EMS organization. Organizations will be providing the total compensation and hours for their employees by employee category.

However, the Instruments asks organizations to report individuals based upon the position they held at the start of the data collection period. If an employee progresses from an EMT to Paramedic during the course of the year, the instrument requires that the new paramedic’s hours and compensation be in the EMT category.

There are a few possible ways that organizations can ensure that they report their labor costs consistent with the Instrument’s instructions. The easiest is to take a snapshot of the personnel roster at the beginning of the data collection year. Ensure that any employee who changes position during the year be tagged and reported appropriately. Many of the scheduling software platforms have existing additional “other” identifier field in the administration set up for employees. Also, most payroll software platforms have canned reports in their reporting suite that identifies employees with status changes during a particular period. Lastly, you can simply keep a list of any employee who, for reporting purposes, you need to go back and adjust your compensation and hour reporting to ensure you have accounted for their costs consistent with the Cost Collection Instrument.

5. Track Volunteer Time/Hours
Also, in Section 7 of the Instrument, organizations that utilize volunteer labor are required to report the number of hours their volunteers worked during the data collection period. Many EMS organizations that utilize volunteer labor do not currently track their volunteer employee’s time. The organization must establish a process for ensuring that they have a method for tracking the working hours of their volunteer employees during the reporting period. This can be done utilizing various software or manual processes. Whichever way your organization decides to track this information, it will be easier to start the data collection period with an established process.

6. Update/Modify Your Dispatch System & Processes
The Cost Data Collection Instrument requires that the organization to report their average trip time (in minutes) across all service levels (BLS, ALS, etc.) in your primary service area. This is calculated from the time the ambulance leaves the station to when that ambulance is available to take another call.

To ensure that you are capturing the data consistent with the Instrument’s definition of “average trip time,” organizations can either make adjustments to their dispatch software or simply ensure that your dispatchers/communications personnel are accounting for the time it takes your ambulance to return to their service area where the ambulance is “available to take another call.”  For many services transporting long distances to destinations outside their service area, the ambulance is not “available to respond to another call” when they clear the receiving facility. Failing to account for this time is truly not providing CMS with an accurate picture of the costs of providing ambulance services.

7. Snapshot of Vehicle Mileage
Section 9 of the Cost Collection Instruments seeks the total number of miles the organization’s vehicles traveled over the course of the data collection period. The easiest way to get this information is to take a snapshot of the starting mileage on all vehicles (ambulance and non-ambulance) at the start of the data collection year. The agency can take another snapshot at the end of the data collection year. This will ensure that the total agency mileage can be captured for all vehicles for the data collection period.

8. Check Payor Categories
Section 13 of the Instrument asks the EMS organization to report all revenues received by the organization, including those not related to the provision of ground ambulance services. The instrument requires that the organization report revenues in the following payor categories:

• Medicare
• Medicare Managed Care
• Medicaid
• Medicaid Managed Care
• Tricare
• Veteran’s Administration (VA)
• Commercial Insurance
• Worker’s Compensation
• Patient Self-Pay

Many billing software platforms do not distinguish between a standard commercial payor and a worker’s compensation payor. It is important that organizations make modifications to the payor set-up in their billing platform to ensure that they can easily illicit their revenue information according to the required payor categories.

These eight steps are what we believe are the critical initial steps to ensure that your organization can more easily and accurately collect and report your ground ambulance cost data. We believe that cost collection is an important step in our profession’s evolution and will frame the reimbursement structure for years to come.

The AAA has created a great number of resources and tools to assist you and your team when preparing and completing the Cost Collection Instrument.  These can be found by visiting the Cost Collection section of the AAA website. Contact hello@ambulance.org if you have any questions or need assistance.

Recently, one of our ACE Faculty members, Katie Arens had the opportunity to review the CMS Cost Data Collection Survey tool and provide feedback to the administration on any challenges faced while completing the survey.  After completing the test we wanted to provide you with some quick tips on how you can be better prepared and ready to complete the tool successfully.

1. Number one RULE, do not wait until the last minute to complete the survey.  I found that even with having my data ready, we still needed to stop and gather additional information from other departments and wait for their response before we could continue.
2. You need to assign a data entry representative who will be responsible for entering the data as well as a data certifier who will go in once the survey is completed and certify that the data submitted is accurate to the best of your knowledge.  It would be best that both parties are working together during the process.
3. Ensure that all parties within your organization that you may need to pull from will be available during the period of time you are completing the survey, i.e. Accounting/Payables, Human Resources, Operations, Billing, and IT support for both your internal organization, but also your vendors in the event you have software malfunctions.
4. Keep track of where you are inputting data, it’s easy within the survey to enter the same data more than once especially when reporting costs.  As you enter your numbers, highlight them on your own documentation so you know you already reported in a previous section of the tool.  Do not report twice, if you feel you reported it in the wrong section of the survey, you can remove it and replace it where you feel it fits best.
5. Take your time, don’t guess when responding.  When in doubt, STOP and reach out to your resources to ensure you are reporting accurately. AAA will have plenty of support to assist you during this process if you are unsure.

Since the survey is not live for all Ambulance Providers, the best way to be prepared NOW is to gain access to AMBER and go through each section of the survey now so you can ensure your systems are set up for the coming year(s) to capture your data easily in a reportable manner.  Continue to review AMBER throughout the year to make sure you remain familiar with the sections you need to report on and provide feedback to various departments that need to be involved.

CMS is hosting a Medicare Learning Matters event on December 5, 2019 from 1:30 – 3:00 EST on Ground Ambulance Data Collection. From the MLN article:

During this call, get an overview of the new Ground Ambulance Data Collection system, including:

• Background
• Selection of organizations required to report
• Detailed discussion of the Data Collection Instrument

A question and answer session follows the presentation; however, you may email questions in advance to AmbulanceDataCollection@cms.hhs.gov with “December 5 Call” in the subject line. These questions may be addressed during the call or used for other materials following the call. For more Information, including providers selected for the first round of reporting, see the Ambulance Services Center webpage, CY 2020 Physician Fee Schedule final rule, and Bipartisan Budget Act of 2018.

Register now for this important event!

November 1, 2019  the Centers for Medicare & Medicaid Services (CMS) released the final rule on the “Establishment of an Ambulance Data Collection System”. The rule was issued as part of the “Medicare Program; CY 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies” [CMS-1715-F and IFC]. The final rule is scheduled for official publication in the November 15 issue of the Federal Register.

The AAA is currently reviewing the final rule to determine changes on the ambulance data collection system from the policies as outlined in the proposed rule of August 15. The proposed rule set forth a system utilizing a survey tool and sampling of ambulance service providers and suppliers as directed by Congress and supported by the AAA. The AAA did, however, submit comments with suggestions as how to fine-tune the process and tool. The AAA also submitted a second letter on the section of the proposal rule making changes related to the physician certification statement (PCS).

We will be issuing a follow up Member Advisory next week with the specific final policy changes on the ambulance data collection system and PCS outlined in the final rule.

Final Rule

Data Collection Instrument – FINAL

2020 Selected Providers and Suppliers

FAQ’s

Quick Reference Guide

There is a widespread recognition in the industry that reimbursement doesn’t fully take into account the costs of service readiness. But until 2020, we haven’t had data to support that understanding. The new cost data collection requirements give us that opportunity IF we are able to gather and report readiness data effectively and accurately. As part of our Quick Takes series, we talk about these issues and give some things to think about in your service right away.

With the release of the new accounting manual, a new tool is available for preparing your service for the new cost reporting (and for getting better financial metrics). As part of our Quick Takes series, we provide a bit of background, and share a helpful process with the new manual: crosswalking.

The data collection that launches in less than 10 months will include a wide variety of elements. Service area and service mix may seem like minor pieces of the collection, but they play a big role in analysis of utilization. As part of our Quick Takes series, we identify some questions you should be able to answer about YOUR service in order to be ready.

Medicare Utilization and Service Volume data will be key in the upcoming CMS data collection efforts. As part of our Quick Takes series, here’s a review of some basics, as well as a look at some limitations of the current system.

We get questions regularly about why data collection is here, why it’s important, and why anybody should care. As part of our Quick Takes series, here’s a brief bit of context to help fill in some gaps!

Huh? What’s dimension compression – and what does it have to do with booking expenditures? As part of our Quick Takes series, here’s a brief overview with some examples!

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

Overview

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).

Introduction

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 mbianchi@ambulance.org.

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.