By Kim Stanley & Matt Zavadsky
EMS systems across the country are transitioning from a transport-driven reimbursement model to one centered on patient care and clinical value. Historically, payment has been tied almost exclusively to transporting patients to an emergency department — even in cases where on-scene treatment was clinically appropriate and in the patient’s best interest.
As healthcare continues its shift toward value-based reimbursement, agencies that bill for treatment-in-place (TIP) services are discovering measurable financial, operational and clinical advantages.
| MORE: Treatment in place: The future of EMS … and yes, someone has to pay for it
Recognizing the value of care delivered on scene
EMS clinicians routinely assess, treat and stabilize patients who ultimately do not require transport. These encounters require trained personnel, medical supplies, documentation and vehicle utilization, yet agencies that do not bill for TIP services receive no reimbursement for this care. Implementing TIP billing ensures that compensation reflects the actual clinical services provided rather than limiting payment solely to transportation.
Evolving reimbursement landscape
Although traditional Medicare does not currently cover TIP services, the reimbursement environment is beginning to change. Commercial insurers, Medicare Advantage plans, and both traditional and Medicaid Managed Care Organizations are increasingly recognizing TIP services as reimbursable healthcare encounters.
Recent financial analysis from PWW A|G, based on EMS|MC claims data indicates that approximately 38.8% of billed TIP claims are reimbursed by insurers or patients. While this percentage may initially appear modest, agencies that bill for these services receive an average reimbursement of $397.59 per claim, representing meaningful revenue that would otherwise be forfeited.
Reimbursement levels also vary significantly by region and are closely tied to the amount charged. In the West region, the average TIP charge is approximately $2,119, with an average reimbursement of $1,151. In contrast, the Southeast region averages $212 in charges and $144 in reimbursement.
These figures highlight an important reality: reimbursement often correlates with established charge structures, reinforcing the importance of thoughtful pricing strategies.
Legislative and regulatory considerations
Nationally, EMS leaders continue advocating for federal reimbursement for treatment-in-place services under traditional Medicare. Despite these efforts, industry data from GADCS suggests that only 11% of agencies currently bill for TIP services. This low adoption rate may stem from uncertainty about collection rates, payer policies, regulatory concerns, or concerns about patients becoming responsible for the bill if their insurance does not reimburse for TIP.
However, federal guidance has clarified certain compliance issues. The Office of Inspector General has indicated that waiving appropriate coinsurance or deductibles for TIP services — when done in accordance with policy — would not necessarily violate anti-kickback statutes. This clarification reduces perceived legal risk and may encourage broader adoption.
At the state level, legislative momentum is also growing. Several states considering balance billing protections are incorporating provisions requiring state-regulated insurers to cover treatment-in-place services, signaling increased recognition of EMS as a healthcare provider rather than solely a transportation service.
Establishing appropriate charges
As commercial insurers expand coverage for TIP services, reimbursement levels are increasingly comparable to payments for actual patient transport. In some cases, insurers intentionally align TIP reimbursement with transport reimbursement to avoid financially penalizing agencies for making clinically appropriate non-transport decisions.
This approach mirrors precedent set by the CMS ET3 (Emergency Triage, Treat and Transport) model, which reimbursed treatment-in-place encounters at rates equivalent to transport payments. The intent was clear: agencies should not be financially disadvantaged when providing appropriate care that avoids unnecessary transport.
Given the clinical value, resource utilization and payer trends, many industry experts recommend that agencies set TIP charges equal to — or close to — their transport base rates. Agencies that establish nominal fees often see correspondingly nominal reimbursement, while those with realistic charge structures tend to achieve stronger payment outcomes.
Developing a clear billing policy
Successful TIP billing programs rely on well-defined internal policies to ensure consistency and transparency. Agencies have flexibility to determine when charges apply, provided policies are clearly documented and uniformly enforced.
For example, some agencies bill whenever a patient assessment is performed, including vital signs and clinical evaluation. Others limit billing to encounters involving Advanced Life Support (ALS) interventions. Many agencies also choose to waive charges in specific situations, such as:
- Lift assists without medical assessment
- Third-party 911 calls where the patient did not request service
- Community-requested welfare checks
Policy flexibility allows agencies to balance financial sustainability with community expectations and local service priorities.
Positioning EMS for the future
Billing for treatment-in-place services is not merely a revenue enhancement strategy — it represents a broader evolution in how EMS fits into the healthcare continuum. Agencies that implement TIP billing strengthen financial stability, demonstrate measurable clinical value, and align themselves with modern healthcare payment models focused on outcomes rather than volume.
As reimbursement policies continue to evolve and payer recognition expands, agencies that proactively establish billing structures, pricing strategies and clear policies will be best positioned to thrive. Treatment-in-place billing reflects a simple but powerful principle: EMS should be compensated for the care it provides, not just the miles it drives.
ABOUT THE AUTHORS
Kim Stanley is the chief client advocacy officer for EMS|MC.
