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5 immediate action steps for Ambulance Cost Data Collection participants

Follow these five steps to save time, ensure accuracy and submit the data CMS requires to prevent a 10% reduction in EMS reimbursement for an entire year


If your ambulance service has been selected to participate in the first year CMS Ambulance Cost Data Collection program, and you fail to submit the complete required data sought by CMS, your agency will be subject to a 10% reduction in reimbursement for an entire year following.

AP Photo/Julio Cortez

If your ambulance service has been selected to participate in the first year CMS Ambulance Cost Data Collection program (which begins on January 1, 2020), there are five immediate steps you must take. Over 2,600 ambulance services nationwide have been chosen to submit their cost data through the CMS online survey instrument in the first year of the process. That means there’s a one-in-four chance your agency is one of them. If you weren’t chosen this year, you will be over the course of the three subsequent years.

If your agency was chosen, and you fail to submit the complete required data sought by CMS, your agency will be subject to a 10% reduction in reimbursement for an entire year following. So be sure you pay attention to this process and meet all CMS deadlines.

If your agency was chosen, there are five immediate steps your agency needs to take.

1. Notify your MAC of your intended data collection period

In recent days, the Medicare Administrative Contractors (MACs) have been sending the official notifications to the selected ambulance organizations. In those notification letters, the MACs are asking the selected ambulance services to report – within 30 days of the date of the notification – the cost collection period they will be using. Ambulance services selected to participate in the cost data collection program are permitted to either use a calendar year (CY) or a fiscal year (FY) data collection period – whichever corresponds to their normal accounting practices.

So, the first, immediate step you must take is to notify your MAC of your 12-month data collection period. This may be Calendar Year 2020 (starting Jan. 1, 2020, through Dec. 31, 2020) or Fiscal Year 2020 (for example, starting July 1, 2020, and running through June 30, 2021, or whatever fiscal year your organization uses). Your reporting of this critical piece of information should be in accordance with the notification letter sent by your MAC; that letter will indicate the website or e-mail address you must use to report this information.

Be aware that this obligation could be due as soon as early December for your organization! Check your MAC notification letter and review it carefully.

2. Take a January 1 ‘snapshot’ of your staff

The CMS cost data collection survey format has some rather unusual aspects to it. As one key example, CMS will require you to report your EMS field staff for the entire year, according to the positions they held as of the beginning of the reporting period. So, if your organization is using a Calendar Year 2020 reporting period, your classification of your EMS field provider staff (e.g., EMTs, paramedics, etc.) is based on their classifications as of January 1.

In other words, if your organization employs an EMT-Basic on January 1, but later in the year, that employee achieves her EMT-Paramedic certification (congratulations!), for CMS cost data reporting purposes, that employee gets included in the EMT-Basic “bucket” for the year’s employee count because she was an EMT-Basic on January 1. Remember, if your agency uses a fiscal year for data collection purposes, this determination would be based on the employee’s classification on the first day of your fiscal year.

For this reason, it is critical that your agency have the ability to produce a start-of-year “snapshot” that will easily allow you to classify your workforce and their positions on the first day of that 12-month period. You may be able to go back and re-create this later in the year, but taking a few minutes to document this information at the start of the year will save you a lot of time and trouble when you’re trying to go back and figure it all out after the year ends.

3. Be ready to track the required information in the required formats

Be aware that the CMS cost data collection process will ask you many questions and, in some cases, require your organization to report data in ways that it may not be accustomed to. In some cases, these cost data collection methods may seem to be at odds with standard accounting practices.

So, before your cost data collection year begins (which for most will be on January 1), your agency must be ready to start collecting information from Day 1 in the CMS-required formats.

Here’s a key example:

Normally, from an accounting standpoint, your agency would assign staff costs to the appropriate budget category based on that person’s actual position. So, if you had an administrator who occasionally took ambulance calls, you might assign part of that person’s salary and benefits to administration and part to operations. However, the CMS cost data collection project will require you to report all of that person’s hours worked under the “EMT/Response Staff” category if they performed any EMS patient care during the year. That’s far different than how an EMS agency would normally account for the hours of an employee who performed both response and administrative roles within an agency in the course of the year.

Trust us when we tell you that it will be much easier for your agency to assemble the required information after the year ends if you are tracking it in the required CMS formats throughout the whole year, compared to if you go back and try to recreate it after the fact. So, your agency should set up a spreadsheet or other tool that faithfully tracks the required CMS information and start completing that for every month of the year – starting January 1 (if you are using the calendar year data collection period).

4. Get your outside contributors to start compiling information as well

The fourth immediate step that ambulance services should take if they’ve been selected to participate in the CMS cost data collection survey is to get any agencies or organizations that contribute to your costs or revenues to start compiling that information in the required format so that you can report it.

This may apply to a nonprofit, community ambulance service that gets contributions from local governments. Or subsidiary companies with a parent organization that provides centralized services for your local operation. Or an ambulance service operated by a hospital that shares costs with other hospital departments. For instance, if your agency uses a station or facility provided by a local government agency, or has personnel benefits paid by a municipality, or gets its vehicle fuel at the city gas pumps, or receives local tax support as part of its revenues, or has its billing done by a central office of your parent company, your agency will need to compile that information and be able to report that as part of your costs and revenues during your 12-month reporting period.

Some EMS agencies do not have a complete picture of the exact dollar value and extent of the contributions made by local governments, parent organizations or other outside entities toward their operations, costs or revenues. Between now and the beginning of the year, your agency – if selected to participate in the CMS cost data collection project – must huddle with those supporting local governments or central offices and educate them about being able to report these subsidies and benefits in the required CMS format. Again, this is something you will find easier to handle if the information is collected and reported in the proper format starting at the beginning of the year, rather than trying to piece it together at the end.

In the same vein, if your agency uses an outside billing company, you will want to promptly let them know that you’ve been selected for cost data reporting – and work with them to be able to report necessary information in the format in which you’ll need it. The CMS cost collection instrument, for example, requires that your revenues be broken down by payor category and that you be able to allocate costs by levels of service. If you use an outside billing company, they will be key in helping you to obtain and report the necessary data to CMS.

5. Read the CMS cost data collection instrument – now!

Finally, any ambulance service that has been selected to participate in cost data collection should – immediately – read the actual CMS Ground Ambulance Data Collection Instrument. This document contains the template for the online survey and specifies precisely how you will be required to report your data once the 12-month collection period ends. You will have 5 months after the end of that collection period to complete your reporting. Again, if you don’t, your agency will be subject to a 10% reduction in its Medicare reimbursement for the following year.

To see the complete CMS cost data collection survey instrument, and to learn how CMS will be requiring your data to be submitted, click here.

PWW will be publishing much more content and educational material on the CMS ambulance cost data collection program in the near future. But, for the short term, as 2020 approaches, these five steps are the most immediate and pressing for those ambulance services that have been selected.

For over 20 years, PWW has been the nation’s leading EMS industry law firm. PWW attorneys and consultants have decades of hands-on experience providing EMS, managing ambulance services and advising public, private and non-profit clients across the U.S.

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