Ground Ambulance Cost Data Collection- How’s it going?
By Chuck Humphrey, B.A., EMT-B, CAC, CACO, CADS, *
Was Your Agency Selected?
Was your EMS agency selected in Year One or Year Two to be mandated to collect and report cost data? If your answer is YES, then you should be well into the thick of pulling together all of those cost data points you need to report in 2023.
Your agency would have been notified if you were selected. If you aren’t sure, you can visit the CMS website at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AmbulanceFeeSchedule/Ground-Ambulance-Services-Data-Collection-System where two Zip Files containing the identities of those organizations that were chosen. Be sure to check this site out if you are still unsure that your agency is included in the first two rounds.
Yes, the project is still on!
There was some confusion in the ambulance community over the announcement that Congress is allowing for a delay in reporting by the government agency MedPAC to Congress. Don’t confuse this delay with delay in reporting. Â
It’s still a go!
5 Months…
The reporting tool will go Live beginning on January 1, 2023. Those of you reporting using a calendar year are now collecting cost data to submit. Beginning at the end of that one-year period, you will then have 5 months to report the data. If you are reporting using a fiscal year (July to June) then you’ll have 5 months to report following the close of the fiscal period you reported at the beginning of the process.
If you have not yet been chosen then you will be receiving notice for your selection in either the Year Three or Year Four collection space.
Watch your mailbox for incoming notifications!
Some things to consider…
I have to say CMS has done an exceptional job with the reporting tool contractor Rand Corporation in keeping a dialogue going for this project. A number of webinars have been offered, including recent Q&A sessions that are quite informative. The presenters have done a nice job answering questions and breaking out some of the more perplexing parts of the process.Â
Here are a few things that I’ve pulled from participating in those sessions that may help you pull the data to ready for reporting.
A Volunteer doesn’t earn anything…right?
Without a doubt, the part of the process to report labor costs can be very confusing. One of the frequent questions is how a volunteer is defined for those organizations that use volunteers.
CMS is using the Fair Labor Standards Act definition which basically defines a volunteer as any individual who gives their time to your organization and does not earn at least minimum wage. Now you probably are thinking… A volunteer doesn’t earn anything…right? They volunteer.
Well…sometimes they don’t earn anything. But, then again, other times a volunteer does earn something, say a nominal stipend per call or some kind of equipment rewards and those kinds of special arrangements. Of course, I’m assuming that you’ve vetted your rewards program or stipend program via qualified legal counsel and have checked in with your accountant as to how these practices affect your tax status.
Dual Roles
Another part of the labor section that causes a boatload of confusion up to this point are the staff members in your organization that play dual roles.
What about the fire fighter that pulls ground ambulance street time? What about the police officer who has responsibility to pull from his patrol and complete the ambulance crew?
Well, if any one staff member pulls any time participating in ground ambulance transports, your agency must account for the cost of the time they spend in the EMS rig. While there is no one method of allocating these costs, CMS is urging agencies to use a defensible method of allocating time spent on the ambulance versus the dual-role staff members other responsibilities.
The easiest way is for some kind of percentage break out.
For example, if the fire engine rolls on 65% of the calls in assist to EMS then it would be reasonable to allocate 65% of those dual-role staff members’ time to the EMS cost or 65% of those staff members’ compensation.
The message here is there is no requirement to compile the time down to the individual minutes and seconds, but there is a requirement that the time reported be a defensible formula for calculating what is being reported and that the formula is used consistently where applicable.
How they start is how they are reported!
Here’s one that is tripping up the folks who are collecting data to be reported.
What if, John EMT is a paid staffer, but decides to step down from his full-time gig at the ambulance service mid-year and moves to volunteering because John has taken a full-time job outside of EMS.
Because John EMT began the year as a paid staffer, then his hours worked and paid would be included as if John were a paid employee for the entire year.
There’s more…
But we’ll wrap up here and pick this topic up another time. Â
Our parting message…if you’re agency has been chosen, NOW is the time to collect the data. DON’T WAIT! Now is the time to answer the complex questions, collect the numbers and get ready for reporting day!!
*Chuck Humphrey is the Senior Director of Compliance and a Territory Sales Manager for Quick Med Claims. He is one of our industry experts with over 30 years of experience in the EMS industry.
