Friday, December 7, 2012

MedPAC – The Ambulance Industry’s Grinch

MedPAC- A.K.A. Grinch!

The ambulance industry now has a Grinch!

That Grinch, MedPAC, looks to snatch a Merry Christmas from the EMS industry thanks to recommendations handed up to Congress in November.

MedPAC, short for the Medicare Payment Advisory Commission is the independent Congressional agency that advises Congress on issues affecting the Medicare program. The commission dropped a bomb on the ambulance industry by making some of the most concerning recommendations our industry has ever seen. 

We advise you to read on and not take this matter lightly. If Congress follows MedPAC’s lead this time, the changes could be sweeping and hit your department smack dab in your bottom line.

Remember, MedPAC’s statutory mandate is very broad and when they speak; Congress listens. Frankly, it’s why Congress created it in the first place. Seemingly experts combined to provide Congress with the data and analysis it needs to act on Medicare matters.

Ambulance in the Cross-Hairs

Ambulance seems to be very much in MedPAC’s cross-hairs right now.

Fresh off a Government Accounting Office (GAO) report that showed (even though most of us think the data is skewed) a few key things… 1) That reimbursements have “caught-up” and are no longer drastically under-funding EMS nationwide and  2) BLS non-emergency payments have risen drastically, with special emphasis on BLS NE’s as related to dialysis transports.

With this data in hand, it seems MedPAC is out to rectify what they see as an ambulance payment imbalance.

November Recommendations

Broken down in pieces, here is what MedPAC is passing up to Congress to consider in changes to Medicare payment policy for the ambulance industry for 2013.

Fee Schedule Rebalancing

MedPAC is calling for Congress to lower the reimbursement fee schedule amounts paid for BLS Non-Emergency transports while re-distributing the dollars to all other levels of service. Their recommendation is for BLS Non-Emergency base-rate payments to be reduced by 5.7% with all other levels of service payments increased across the board at a rate of 2.8%.

Geographically Isolated Areas

The recommendations call for the inception of something called “Geographically Isolated Areas.“ Ambulance services located within these to-be-defined boundaries, across the nation, would be reimbursed at a higher rate (similar to the “Super-Rural” concept) but only if a service amasses fewer than 600 runs per year.

New Medical Necessity Requirements

Medical necessity, always a hot potato, is addressed in the recommendations.  MedPAC believes that Congress should mandate that new national guidelines be established to more precisely define medical necessity, including for both emergency and non-emergency ambulance transports.

Audit Activity to Increase

Expect more audits!

MedPAC is proposing that audit activity be increased. The commission specifically made a call for increased auditing of BLS Non-Emergency transports, especially those that are tied to the transportation of patients requiring dialysis.

Analysis

We’ve already had some of our clients ask our opinion on how we feel they will be affected. 

Our answer- it’s unknown.

None of what we’ve outlined above is binding. Congress can accept all MedPAC’s recommendations, accept none of them, or accept some of them. In addition, with the “Fiscal Cliff” looming, we doubt that Congress is really focused on Medicare changes to the ambulance industry at this very minute.

However, that’s not to say that all or some of these recommendations won’t be slipped into some larger piece of legislation that may quickly move on the heels of the current discussions on Capitol Hill.

Worst-Case Scenario

Frankly, we believe that your department should gear-up for at least parts of these recommendations to be implemented.

So be prepared.

At least run some numbers and think about how the worst-case scenario will impact your service. Expect the worst and hope for the best may not be a bad course of action to follow at this point. If your department is heavily reliant on BLS Non-Emergencies and you do a fair amount of dialysis-type transports, then you potentially have the most to lose and the most to be concerned about. 

Plan Ahead

Ask a few key questions, such as…  How can we diversify?  How long has it been since we reviewed call-intake policies?  Are we asking all the right questions to insure our trips are meeting current medical-necessity guidelines?  What cost-saving measures can we implement?  If we lose BLS NE dollars will be offset by the proposed increase in other payment levels (Emergency runs, ALS runs, etc.)? Can we come up with creative ways to raise funds to offset any potential losses? Is now the time to ask for an increase in local funding/taxes?

Historical Data is Key for Analysis

Are you able to pull down the historical billing data that you need?  Enhanced clients have a wealth of information at their disposal. Looking back at where you’ve been with regards to past billable trip volume while taking steps to calculate your department’s payer mix and level-of-service distribution will help you prepare.

Once you’ve pulled the numbers, then apply some reasonable forecasting techniques. Adjust your budget. Since Medicare dollars account for a large portion of EMS payments, especially in areas where you may serve a graying population take a hard look at where these numbers will go and what that equates to regarding your pending decisions for staffing levels and resource allocation.

We’re Standing By
We’ll continue to monitor all the communications and pledge to provide you with as much information as we possibly can as decisions are made in Washington. In the meantime, use the tools we offer you, as a client. Your access to report data exceeds industry standards, so everything you need is right there at your fingertips. All you have to do is make the numbers fit into your individual forecasting model.

Not an Enhanced client?  It’s time to become one. Contact us today to find out how you can begin to tap into receiving the billing data you need to plan and prepare for what could become some of the biggest changes in the industry in a long time!
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