As COVID-19 continues spreading across the US, fire and EMS agencies are increasingly serving on the front lines of containing and mitigating the virus. The demands of caring for COVID-19 patients and routine EMS patients is placing great strains on both pre-hospital EMS systems and hospital systems. In light of the need to develop a more efficient way to treat and transport these patients, the Centers for Medicare and Medicaid Services (CMS) released one of the most significant updates (PDF) to the Ambulance Fee Schedule (AFS) since its creation twenty years ago. It is important to note, these new provisions are temporary and will be rescinded when the U.S. Department of Health and Human Services concludes their public health emergency which Secretary Alex Azar declared on January 27. As of this writing, Secretary Azar has not indicated an anticipated end date for the COVID-19 emergency declaration.
In general CMS had made the following changes to the AFS:
- Transportation to Alternative Destinations: Historically, the AFS has required fire departments and EMS agencies to transport emergency patients to hospitals or landing zones in order to receive reimbursement. Under CMS’ new proposal, all ground ambulance suppliers and providers will be permitted to transport patients, based on their State or Local EMS agency’s protocols, to alternative destinations. CMS identifies these locations as including physicians’ offices, urgent care clinics, testing sites, ambulatory surgery centers, temporary facilities supporting hospital operations and even a beneficiary’s own home. While the medical necessity of the transport must still be documented, these transports will be permitted on both an emergency and non-emergency basis. This new option will be especially helpful for fire departments and EMS agencies struggling to get patients to appropriate care facilities and enduring ambulance units being out of service due to extended wait times when transferring a patient from their ambulance to a hospital.
- Telehealth Options: CMS’ new policies significantly expand the ability of physicians to utilize telehealth when providing both routine and emergency healthcare to Medicare beneficiaries. While only providers are permitted to provide these telehealth services, they may contract with ambulance agencies to facilitate these services. If an ambulance agency chooses to assist in facilitating telehealth, they will be unable to bill CMS directly and must seek payment directly from the physician or other provider performing the telehealth services.
- Pause on Prior Authorization Model: As part of this announcement, CMS also announced that they will be temporarily suspending their pilot project to require prior authorization for repetitive, pre-scheduled non-emergency transports
The IAFC applauds the CMS for issuing these new policy updates which will assist in lifting the response burden placed on pre-hospital EMS agencies as well as hospitals. The IAFC plans to continue working with CMS to identify other CMS policies, such as the prohibition on providing treatment without transportation, which could be eased to further improve efficiencies in fire and EMS agencies’ responses to COVID patients.
As fire chiefs review these new policies and consider updating their EMS protocols, it will be important to remember that these policy changes are temporary and that CMS plans to reinstate their prohibition on transportation to alternative destinations once the current public health emergency ends. The IAFC strongly encourages CMS to make these policy changes permanent; however, at this time, CMS has not expressed plans to extend these policy changes beyond the COVID-19 public health emergency.
The IAFC also would like to remind fire chiefs that they are welcome to contact the IAFC COVID-19 Task Force with any questions or concerns that they would like to share.
Pete Lawrence is a division chief with the Oceanside (CA) Fire Department and is a subject matter expert in EMS reimbursement and Medicare payment policies. Evan Davis is the IAFC's government relations strategic manager and liaison to the EMS Section.