Proposed Rule Would Bring Negative Reimbursement Changes for the Ambulance Industry

The Centers for Medicare and Medicaid Services (CMS) published a Proposed Rule today that could have a big impact on your bottom line. If the Proposed Rule is implemented without modification, ambulance services will almost certainly see a decrease in Medicare reimbursement in the coming years. 
 
In this Proposed Rule, CMS would require ambulance services to start reporting mileage to the nearest tenth of a mile for dates of service on or after January 1, 2011. This would apply to all trips up to 100 loaded miles. Currently, CMS instructs all ambulance services to round up all fractional mileage to the next whole number. CMS is estimating that this could “save” Medicare up to $80 million a year! 
 
In addition, the Rule proposes to reduce the annual ambulance reimbursement update by what is called the “Multi-Factor Productivity” (MFP) adjustment, implemented by the Healthcare Reform Bill.   Application of this new adjustment could have the effect of decreasing reimbursement amounts from one year to the next, and it is expected that the change will reduce Medicare reimbursement by around $30 million in the first year that it takes effect. 
 
CMS is also proposing two changes to the regulatory requirements for enrolling and maintaining active enrollment status in the Medicare program. These changes will primarily affect air ambulance services, although one proposed change could impact all ambulance providers and suppliers, as it requires the submission of “certifications” when applying for enrollment. 
 
Finally, the proposed rule will also implement the 2% urban, 3% rural, and 22.6% “super rural” bonus payments until the end of this year, as required by the Healthcare Reform Bill. 
 
These provisions are buried in a lengthy Proposed Rule that primarily deals with new policies under the Physician Fee Schedule. CLICK HERE to access a copy of the official Proposed Rule and to read more about its potential impact.  
 
Sample Letter
Since this is a proposed rule, ambulance services and other affected organizations have an opportunity to comment on it until August 24, 2010.  PWW has already submitted a comment letter to CMS on behalf of the ambulance industry and you can CLICK HERE to download a copy of our letter in PDF format.
Additionally, PWW has drafted a model comment letter that is now available for you to download.  Ambulance services can use the model letter to comment on the negative impact that this Proposed Rule would have on ambulance reimbursement.  Simply download the letter in Word format and follow the instructions to customize the model letter for your organization.  CLICK HERE to view instructions on how to submit comments to CMS and to download PWW's model comment letter.