The Emergency Triage, Treat, and Transport (ET3) program, the Center for Medicare and Medicaid Innovation’s (CMMI)’s proposed model to test new payment policies, has been one of the hottest topics in the EMS industry this year. CMMI shook up the federal policy and political world in February when the agency announced the ET3 program, which finally will reimburse participating EMS agencies for either treating patients on-scene or transporting them to alternative destinations. While none of these concepts are new to the fire and emergency service, it’s nonetheless an important step towards updating the Medicare Ambulance Fee Schedule to reflect the full capabilities of America’s fire departments.
The rules that will govern the ET3 program have continued to evolve over the summer, and it’s crucial for anyone interested in ET3 to understand these new policies. Many of these updates may make it easier for agencies to participate in ET3, so make sure to take close note of these changes if you’re still considering whether to apply for ET3.
Application Deadline
One of the most important announcements from CMMI came with their decision to extend the application period, which now will close on October 5 at 11:59 PM ET. This two-week extension will be helpful for agencies still working on fine-tuning their application and complete last-minute preparations.
Availability of New Interventions
Initially, ET3 applicants were required to demonstrate how they will have either the treatment in place (TIP) option and/or the transportation to alternative destinations option available on a 24/7 basis when the program starts next year. CMMI noted concerns by agencies who feared being unable to have the new interventions available around-the-clock. As a result, CMMI has revised these rules to require that applicants demonstrate how they will eventually achieve 24/7 availability of these interventions at some point during the model period.
This is an especially important update as it will allow fire departments to apply to participate in the ET3 program, even if they still are finalizing discussions and agreements with partnering healthcare providers and destinations. CMMI encourages applicants to come as close as possible to achieving 24/7 coverage. However, the easing of this requirement will be helpful for those agencies which are still developing their partnership agreements with other healthcare providers and destinations.
Multiple Billing from Patient Encounter
CMMI noted that they have received numerous questions about how agencies could bill for scenarios when they begin providing the TIP intervention, but a sudden deterioration in the patient’s condition forces crew to transport the patient to an emergent or non-emergent destination. In these cases, the EMS agencies only will be permitted to bill for the patient’s transportation and not for the TIP intervention. However, if a qualifying healthcare practitioner (QHP) has already evaluated the patient before the decision was made to transport, then the QHP may bill for this evaluation despite the patient ultimately being transported to an emergent or non-emergent destination.
Interrupted QHP Consultation
CMMI also received questions from both rural and urban agencies alike who were concerned about how to handle cases where an interruption occurs in the QHP consultation during the TIP intervention. These agencies were unsure if they would be able to bill for the TIP intervention if the two-way voice/video communication with a QHP was interrupted due to a lack of connectivity for their smartphone or other devices. In these cases, CMMI clarified that the agency and QHP both may still bill if the consultation had been substantially completed and all parties agreed with the decision not to transport the patient.
Interaction with Medicaid
While ET3 always has been only focused on providing new interventions for Medicare fee-for-service beneficiaries, CMMI reiterated that this would continue to be true when the ET3 program launches next year. However, CMMI has developed resources to assist state Medicaid programs in evaluating the ET3 program and identifying potential opportunities for state Medicaid programs to develop policies which support ET3-like interventions for Medicaid beneficiaries. It is important to note though that any changes to a state Medicaid program must be made by the state itself and cannot be made by CMMI or the participating agency. More information on these resources can be found here (pdf).
The ET3 program continues to be an important opportunity for EMS agencies to prove that proper reimbursement policies can drive EMS innovations which lead to better, and more efficient, patient care. Make sure to take some time and review these new updates, and CMMI’s other ET3 resources, if you’re still planning to apply to participate in the ET3 model policy.
Evan Davis is a strategic manager in government relations at the IAFC.