Show Your Math: Ambulance Add-On Bonuses Extended (at a Price)

The ambulance add-on payments that give 2% urban, 3% rural, and 22.6% super-rural bonuses to Medicare’s ground ambulance base rates have been retroactively reinstated to January 1, 2018, and extended through the end of 2022. This is first time such a long extension has been granted, but it comes at a significant price. 

For ambulance service suppliers that do repetitive dialysis transports, an additional 13% discount will be applied to the base rate for these calls. This is on top of the 10% already being cut for these trips. The initial draft of the legislation anticipated an additional 22% cut (32% total) being necessary to fund the add-ons, but that figure was negotiated down to 13% (23% total). This additional cut is set to begin in October.

But that’s not the only price we’re paying for the five-year extension of the add-ons. Beginning in January 2020, all ambulance service suppliers will be required to submit cost reports. These cost reports will give Congress data to determine if the add-ons are truly necessary and should therefore be made permanent. While the details of this are not yet set in stone (the new rule has to go through a notice and comment period that will allow citizens to chime in on the manner and method of the final cost reporting requirements), the Comprehensive Operations, Sustainability, and Transport Act of 2017 includes reporting of the following:

1. The aggregate cost of operation and volume of services; 
2. The costs and volume of services for various functional accounts and subaccounts; 
3. Rates by category of patient and class of purchaser;
4. Capital assets, including (as appropriate) capital funds, debt service, lease agreements used in lieu of capital funds, and the value of land, facilities, and equipment;
5. Discharge and bill data;
6. Whether the supplier is part of an emergency services department, a governmental organization, or another type of entity;
7. The number of hours in a week during which the supplier is available for furnishing ground ambulance services;
8. The average number of volunteer hours a week used by the supplier.

The bill also allows for the suspension of payments to any ambulance service supplier who does not submit a “complete, accurate, and timely report” beginning in January 2020. After January 2022 the secretary can also recoup as “overpayments” monies from suppliers who do not submit their cost reports. These teeth are intended to make sure Congress gets accurate data on our income and expenses. 

So, the add-ons are back for now. The price will be felt sooner for services that have dialysis patients, but it will be felt by us all in the end, as we take on the additional burden of cost reporting. We keep telling Congress we need this extra money—now it’s asking us to show them our math if we want the add-ons to be made permanent. Get ready: Cost reporting is finally coming to EMS. 

Christopher Kelly is a lawyer who focuses on regulatory healthcare law as it relates to the EMS and ambulance industry. This article is not intended as legal advice. For more information reach Chris at EMS Consultants, Ltd., 800/342-5460, ckelly@emscltd.com.