PRIORITY ISSUES:
As the leading public and private EMS and Ambulance transport advocacy organization representing Ambulance services in the State of Washington, the WAA is uniquely positioned to play a leading role in addressing the challenges to our industry today and in the future. The following outlines our legislative priorities for the 2024 legislative session.
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BALANCE BILLING
Due to the local regulation of ground ambulance services, insurance companies should not put patients in the position of paying the balance of the locally-regulated reimbursement rates for the provision of ground ambulance services because the insurer does not want to pay the rate.
When a patient’s insurance company has indicated that emergency ground ambulance services and/or non-emergency ground ambulance services required to coordinate their care are covered under the plan that the patient has purchased, the insurance company should reimburse the ground ambulance service consistent with the local requirements.
Unfortunately, many insurance companies mislead patients into believing that these essential health services are fully reimbursed, when in fact the insurance company has no intention of providing the reimbursement level that the patient expected. When this situation occurs, local and state laws allow the patient to be billed for the part of the ground ambulance service rate that the insurer refused to pay.
This “balanced billing” option is permitted by local and state laws because of the uniquely and highly regulated role these governments play in selecting and overseeing ground ambulance services in their community. Any “surprise” the patient might experience is due to the insurance company’s deception, not the ambulance service supplier or provider.
Unlike other health care providers, ambulance service suppliers and providers cannot refuse patients when they call 911 or the equivalent emergency response line. Because of this inability to refuse to provide service and other reasons described below, including local and state laws, the ambulance service has no option but to seek the reimbursement amount from the patient.
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EXPANSION OF TREATMENT IN PLACE COVERAGE
We request that the Legislature authorize CMS to reimburse ambulance service providers and suppliers for performing protocol-driven non-reimbursable medical services in responding to COVID-19 cases and transporting patients to facilities other than hospitals.
This coverage will help limit the spread of COVID-19 by keeping patients with mild cases of COVID-19 at home and out of overcrowded hospitals or other facilities where they could expose others to the virus.
Since the Pandemic, the Federal Government issued an unprecedented array of temporary regulatory waivers and new rules to equip the American healthcare system with maximum flexibility to respond to the 2019 Novel Coronavirus (COVID-19) pandemic.
During the COVID 19 PHE, ambulance transports may include any destination that is able to provide treatment to the patient in a manner consistent with state and local Emergency Medical Services (EMS) protocols in use where the services are being furnished.
These destinations may include, but are not limited to: any location that is an alternative site determined to be part of a hospital, Critical Access Hospitals or Skilled Nursing Facilities, community mental health centers, federally qualified health centers (FQHCs), physician’s offices, urgent care facilities, ambulatory surgery centers (ASCs), any other location furnishing dialysis services outside of the ESRD facility, and the beneficiary’s home.
WAA is requesting that these policies continue post-pandemic.
Voluntary & Involuntary BEHAVIORAL HEALTH Transports
Not all ambulance trips start with an emergency. Some individuals in our community may have health concerns that require special medical care or observation while being transported – either to a healthcare institution or treatment center or between facilities.
With any ongoing rollout of new law, such as Ricky’s Law, challenges and barriers may occur or become known through trial and error.
Interfacility Transports
Current policies around interfacility transports are not sustainable. Meeting the cost of IFT involves a thorough understanding of incurred expenses as well as mechanisms for reimbursement.
Preparedness Funding from the state, while most payers make payment for services and equipment provided, identification of alternative funding sources may be necessary to cover the cost of providing “preparedness” (the day-to-day fixed and operating costs of IFT service).
Costs are incurred by an IFT service to assure a constant state of readiness, even if no patients are transported, IFT service assumes additional costs every time a patient is transported.
For IFT, the mileage and hourly expenses may be magnified because transport is
generally over longer distances. The transporting service must pay for fuel, wear and tear on the vehicle, and the time of the personnel. Longer transport times also mean that the personnel must be prepared for more contingencies with the patient, increasing the cost of readiness.
AdditionalLy, many of the problems of an urban service can be magnified in a rural service. Rural providers face additional financial challenges: have difficulty finding trained and experienced personnel. Recruiting can be difficult for rural services.
medicaid Reimbursement Increase
Ambulance providers in the State of Washington have not had an increase in their reimbursement rates for Medicaid transports since 2006, when they were granted a 2% rate increase. Meanwhile costs for wages, equipment and training have continued to rise while the reimbursement rate remains unchanged.
A typical Medicaid transport in the State of Washington pays approximately $135 per transport, one of the lowest state reimbursement rates in the United States.
Currently, ambulance reimbursement rates are so low that the service delivery system is under extreme stress. Providers in many jurisdictions are under financial pressures and unable to cover the costs necessary to run a robust system with short response times.
In 2016 thE Washington State Ambulance Association asked for a review of the reimbursement rates for ambulance transports and a determination was made by the Washington Health Care Authority that the rates for ambulance transports were too low. The HCA found that the “ambulance rates do not provide adequate compensation for the services required.”
OUR REQUEST: that Medicaid reimbursement rate be increased for a stronger EMS system. We request that the State provide a general Medicaid rate increase for Ambulance Transports at a rate of $6.5 million per year - $13 million for the biennium.
The state should provide a general Medicaid rate increase for Ambulance Transports. With approximately 100,000 Medicaid transports per year it would cost approximately $6,500,000 per year to increase Ambulance reimbursements from the Medicaid rate ($135) to the Medicare rate ($265). The Federal government reimburses Medicaid charges for Ambulance services at rates between 50% and 90% of billing costs. With the federal reimbursement rate included it is anticipated that a state appropriation increases of $6,500,000 per year would cover the increased cost to parity with Medicare.
Additionally, cost of labor is directly related to a need for Medicaid reimbursement increase.