CMS Data Release Position Statement

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April 17, 2014 On April 9, the Centers for Medicare and Medicaid Services (CMS) released data describing the number and type of health care services provided by physicians and other health care professionals in 2012. Although extremely different than other health care providers, ambulance services were included in the data release. The American Ambulance Association (AAA) supports increased transparency in the way Medicare pays providers for the care provided to beneficiaries. For example, the AAA continues to encourage the Congress to allow CMS to conduct a survey of ambulance providers to better understand the cost of providing care to Medicare beneficiaries throughout the United States. However, the data set released last week if examined in isolation could lead to confusion among beneficiaries and policymakers. Transparency is only useful if the data provided is meaningful. Thus, we urge those reviewing the data to also consider the context of the current Medicare ambulance payment model. Ambulance services are unique in many ways and differ significantly from other types of Part B providers. They are complex organizations that vary greatly. There are several types of services, including: private, governmental, volunteer, and fire-based services. The vast majority of these services provide emergency and non-emergency (more…)


Stretcher Van Transportation

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June 19, 2013 Issue In the 21st century health care environment in the United States, taxpayers and insurers alike constantly seek ways to reduce health care expenditures. In this context, some have proposed that stretcher van transportation be included as a covered benefit under the Medicare Program. AAA Position The American Ambulance Association opposes the use of stretcher vans to transport patients. Accordingly, the AAA opposes Medicare reimbursement for stretcher van transportation. The AAA is opposed to such a policy because we believe that it is not in the best interest of the patients being transported. Actual experience from across the nation makes it clear that patients are being put at risk every day as a result of being transported in vehicles that are not staffed or equipped to meet their medical needs. Ambulance transportation is a medical service, and includes medically trained EMTs to attend to the patient’s medical health and safety needs. Stretcher vans are a form of non-medical transportation. The AAA believes that it is misguided public policy to blur the distinction between the medical care provided by ambulance services and non-medical transportation such as stretcher van and wheelchair van services. Background Policies vary on this issue (more…)


2013 Response to MedPAC Recommendations

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June 2013 Statement in Response to MedPAC Recommendations Regarding Medicare Payment of Ambulance Services The American Ambulance Association (AAA) appreciates the thoughtful consideration undertaken by the Medicare Payment Advisory Commission (MedPAC) in crafting its final report on Medicare payment of ambulance services. The AAA particularly appreciates recognition by the Commission that six out of seven ambulance service levels are not adequately reimbursed by Medicare. However, the AAA remains very concerned by the MedPAC recommendation to impose payment reductions to nonemergency basic life support (BLS) transports to, in part, offset the cost of increases for the other service levels. The AAA is also concerned about the recommendation to eliminate the additional mileage payments for rural and super rural transports and restructure the payment for ambulance services provided in extremely rural or “super rural” areas. These proposals will have a tremendous negative impact on legitimate ambulance service suppliers and providers nationwide and are not adequately targeted to address the underlying concerns of MedPAC. We look forward to working with MedPAC and the Congress to ensure adequate and stable Medicare payments while working to reform the ambulance fee schedule using more complete data than exists today and to combat fraud and abuse relying (more…)


Medicare Fraud Statement

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May 20, 2013 As the primary association representing ambulance suppliers and providers in the United States, the American Ambulance Association (AAA) condemns Medicare fraud in any form. The AAA is committed to eliminating any improper billing in the Medicare ambulance benefit, and continues to provide education, training, and compliance programs to its members to ensure proper compliance with all Medicare laws and regulations. In fact, as a condition of members in the AAA, entities that provide ambulance services must not be excluded from the Medicare and Medicaid programs. We also provide a series of educational materials, including publishing the Medicare Reference Manual annually, producing webinars on compliance that can be accessed 24/7, and developing best practices. Founded in 1979, the AAA’s Mission is to promote health care policies that ensure excellence in the ambulance services industry. The AAA represents ambulance services across the United States that participate in serving more than 75% of the U.S. population with emergency and nonemergency care and medical transportation services. The Association views prehospital care not only as a public service, but also as an essential part of the total public health care system. Ambulance services are the front line and initial access point of (more…)


Federal Pricing Restrictions

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Federal Restrictions on Pricing Ambulance Services March 10, 2009 This document is designed to provide an overview of what is required under the Federal Anti-Kickback Statute and the Substantially-in-Excess Rule. Introduction One of the questions that is often raised by ambulance service providers involves legal restrictions on discounting. Healthcare facility principals constantly ask ambulance service providers to discount prices for facility responsible transports. Ambulance service providers may believe that they have some pricing flexibility but are concerned that any action they take may subject them and their customers to liability under the Federal Anti-Kickback Statute and the Substantially-in-Excess Rule. Ambulance service providers are urged to consult with their attorneys, accountants and/or healthcare consultants before establishing policies for their companies/facilities. Applications of these laws are fact intensive and a small change in the facts could well lead to a different legal conclusion. This policy document is designed to present the issues and explain the type of analysis required to address the issues. Since the laws in question are criminal in nature and individuals (both providers AND receivers of said services) who violate these laws may be convicted of a felony and jailed for up to five (5) years, it is essential (more…)


H5N1 Pandemic Influenza

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February 9, 2006 Issue It is the position of the American Ambulance Association (AAA) that all ambulance service providers have access to the necessary funding and resources to be prepared and plan for the possibility of a Pandemic flu outbreak. As America ‘s first response and safety net, ambulance services across the country must be included in federal, state and local government efforts to plan and prepare for what may be widespread infection involving H5N1 Influenza. The AAA will further act as a clearinghouse for information to ambulance service providers on preparing and planning for a Pandemic Flu. The following outline provides ambulance service providers across the country with the first steps in preparedness and awareness of the issue. While not intended to be a comprehensive pre-plan, this document provides the basic guidance and suggested references to assist providers in their preparations. Special thanks and recognition is given to the members of the Professional Standards Committee who worked so diligently to provide their professional input and expertise for this document. AAA Position & Background Public health officials have recognized pandemic Flu as a significant public health threat for several years; it is just now coming to the attention of politicians, (more…)


Letter on National Scope of Practice Model (2005)

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January 20, 2005 Ms. Amy Starchville National Association of State EMS Directors 201 Park Washington Court Falls Church, VA 22046-4527 RE: Request for Comments on the National EMS Scope of Practice Model Dear Amy: We appreciate the hard work that the Scope of Practice work group put into the project and thank them for their willingness to allow our comments for consideration. The American Ambulance Association (AAA) remains committed to the improvement of emergency medical services and fully understands the importance of this process as one of the critical steps in implementing the EMS Agenda for the Future. Therefore, we take the opportunity to comment on this very important document with great thought and care as we represent the interests and needs of our members and most importantly the patients they serve. The American Ambulance Association is the primary trade association representing providers of emergency and non-emergency care and medical transportation services. The AAA membership is comprised of over 600 ambulance service providers across the United States that participate in serving more than 75% of the U.S. population. AAA members employ nearly 100,000 EMT’s and paramedics who respond to approximately ten million requests for ambulance services each year. The AAA (more…)


Drug Alteration Policy

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Position on Storage of Medications on Ambulances Issue Ambulance services carry multiple medications and other preparations on their ambulances on a routine basis. They do this so that medics can treat patients exhibiting various medical conditions with state of the art medical care wherever it is needed. Whether it is in the home, work or in public settings medics respond to treat our patients with the best pharmacological interventions available today. Medications that are normally stored in the controlled environments of pharmacies and clinical settings are routinely carried in the less controlled environment of the ambulance. In addition, these medications are routinely transported outside of the ambulance as the medics take medical equipment and these medications to the patient’s side. Emergency Medical Services medications are sometimes exposed to environmental extremes that theoretically might impact the effectiveness of the medication over prolonged exposure times. AAA Position The American Ambulance Association advocates the creation of policy and procedures for the storage of medications. It is the position of the American Ambulance Association that all ambulance services use the approach outlined in the Commission on Accreditation of Ambulance Services standard 203.03.04 which states: “The agency shall have a policy/procedure for the storage of (more…)


Smallpox Vaccination of Health Care Workers

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January 6, 2003 Voluntary Smallpox Vaccination of Health Care Workers: Making An Informed Decision No doubt by now many of you have been contacted by your state or local health departments in relation to the efforts currently under way to prepare for a possible smallpox attack. It is critical to understand that this effort is a direct result of President Bush’s directive in relation to homeland security and in preparation of a possible bio-terrorist attack on our country. The following information is being provided in an effort to help you better understand the president’s initiative and help you in making the determination as to what choices you and your organization have in relation to this effort. Understand that your decision as to whether you participate in the vaccination program or not is entirely your decision and 100% voluntary. Decisions on whether or not you participate in the program should be made carefully and only with a full understanding of the risks, some of them serious, that may be involved. Excellent sources to aid you in this decision process are available on this website and we urge you to review them thoroughly before making your decision. In making your determination you (more…)


Transportation of the Morbidly Obese

August 22, 2002 Issue Patient transferring and handling injuries typically represents at least 50% of health care providers Worker’s Compensation annual costs. Such tasks continue to become more difficult because of the on going health crisis of obesity. The transportation of patients weighing in excess of 500 pounds poses serious challenges to our EMS crews, from the medical management of the vast array of health problems these patients present with, to physically moving the person from one location to another. Request to move patients weighing 500 to 800 pounds or more, can overwhelm the best-prepared EMS provider. AAA Position The American Ambulance Association advocates the creation of policy and procedures, the use of training, continuing education, the use of the most appropriate equipment available to meet the needs of the patient and minimize the chance of injury to workers. Community involvement, pre-planning and request for lift assistance, which assures that EMS personnel are transporting these patients safely and effectively, while providing appropriate care in a respectful manner. Medical and mechanical skills must be balanced to ensure that patient accommodations offer effective and appropriate treatment and timely extrication. Training of EMTs and Paramedics for rendering emergency care to the morbid obese (more…)


EMS Safe Driving Statement

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May 6, 2002 Issue In the 21st century health care environment in the United States, health care providers are attempting to find solutions and systems to reduce the unintended deaths and injuries to hospitalized patients described by the 1999 Institute of Medicine study. Likewise, ambulance providers are challenged to look carefully at themselves to reduce the incidence of death and injury to patients, ambulance service employees and the public due to collisions between ambulances and other vehicles and/or stationary objects. AAA Position The American Ambulance Association is positioning itself to educate its members regarding the high incidence of collisions and provide them with information, technical assistance, and industry “best practices” to substantially reduce or eliminate the risk of ambulance collisions. The AAA recognizes that there may be many causes of ambulance collisions. The AAA also recognizes that a systems approach to safe driving can significantly reduce the risk of collisions and the resultant death or injuries. The AAA also acknowledges that there is scientific evidence that supports a systems approach to safe EMS driving. Background Leaders in the ambulance industry and those who insure the industry are acutely aware of the significant risks associated with driving ambulances, especially under emergency (more…)