Friday, February 23, 2018

Cost Data Collection on the Horizon for EMS

Reality Time

When the Philadelphia Eagles won their very first Super Bowl two weeks ago, the City of Brotherly Love went giddy wild. There were light poles to climb, banners to wave and confetti to throw.

Then…it was reality time.

All that confetti had to be cleaned-up, the banners folded and tucked away in the attic and the reality that football season was over hit (along with the hangovers…dilly, dilly.)

That’s where we all are at now that the Medicare Add-On payments have been extended by Congress for the next five years.

It was a big victory. Finally!

But now it’s reality time for the ambulance industry as we face a new initiative.

Cost Data Collection on the Horizon for EMS
Cost Reporting
When President Trump signed the Bipartisan Budget Act of 2018 into law on February 9th, we all breathed a sigh of relief. But the “fine print” of the law will now usher in a Congressionally-mandated provision requiring the Centers for Medicare and Medicaid Services (CMS) to begin working toward the process of collecting cost data from the ambulance industry.

We all know that whenever the “Feds” mandate anything new that it translates into something that will require more work on our end. This is just inherent in the whole Medicare circle.

However, our industry should tune our brains to how this mandate may just be the golden cow that we have all sought after for some time. The American Ambulance Association put it best this week when they disseminated a communication penned by Kathy Lester of Lester Health Law PLLC.

Lester explains that the cost data collection system that is proposed will allow “…the federal government to collect meaningful data that can be used to address the inadequate reimbursement rates and modernize Medicare ambulance payment policies.”

We agree in principle, if this is the true intent. If this plays out, then the requirement will become a very good thing.

We surmise that the entire American ambulance industry will collectively agree that we can’t continue to work toward brinkmanship every so many years, biting our nails over potentially losing dollars. Plus, the politics needs to be removed from the process and a system that makes sense, based on true facts and figures, be instituted to drive reimbursement levels that adequately fund EMS for the future.

Timeline

There is no need to panic as this new cost reporting requirement is not going to happen overnight. In fact, the plan as detailed by the AAA shows that the full implementation of the system will span out over several years into the future.

The very system to be devised to collect this cost data will not even begin to be built until sometime in 2019. The new bill mandates that there be discussions to include the ambulance industry on how and what data is collected in 2019. Basically there will be no end-user effect for this entire current year in 2018.

Throughout 2019 while the vehicle to gather the data is devised CMS will also identify which providers and suppliers will make up the representative sample that is required within the legislation. Data will then be collected using this new collection vehicle beginning in the years 2020 through 2024. CMS will issue the requests during that 4-year span.

To add some teeth to the mandate, in 2022 there will begin to be a penalty assessed against those ambulance providers and suppliers who are asked to submit data but have not done so to the satisfaction of CMS. At that point, those who fail to meet the requirement will be assessed a 10 percent payment reduction in the year thereafter.

Congress will then review the data collected over that 4-year span after which there will certainly be more discussion regarding the results and how they will affect future reimbursement policies.

The current blueprints for the program call for data collection to happen no less than an every 3-year cycle.

It will be interesting…

It will be interesting come 2022 (or 2023 depending on when the clock begins to tick given the late passage of the extension legislation) what Congress will do when once again faced with the question of extending the Add-Ons. The cost data collection process will not have completely played out by the time the current extension period draws to a close. Plus, we know that the proposed Medicare Payment Advisory Commission (MedPAC) report detailing to Congress the cost collection findings will barely be published in 2023, let alone have been fully reviewed for its relevance and to allow time for a permanent fix.

Will Congress once again extend the Add-Ons or will they hold back to await the final analysis of the data that has been collected via the newly mandated process? If only we could see the future!

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