Ground Emergency Medical Transportation
Fee-for-service supplemental and managed care state directed payments for Medicaid ground emergency medical transportation (GEMT) services have grown in recent years, and the Centers for Medicare & Medicaid Services (CMS) continues to approve GEMT payment programs in the current year. Driven by industry efforts, some states are introducing legislation this year related to new GEMT programs.
GEMT payment programs can benefit everyone, including public providers and Medicaid beneficiaries, and most do not involve new state funds due to the availability of intergovernmental transfers (IGTs), certified public expenditures, and assessments. Because industry consultants initiate and set up many of these programs, it is important that states have their own consultant to help with program development and design, Medicaid financing strategies, and compliance, all of which consider and protect the state’s interests. Those interests may include ensuring adequate financing, allowing for state administrative costs, and limiting potential liability for overpayments due to complex rules that continue to change at the federal level.
Increased Oversight for Ambulance Supplemental Payment Programs
Existing ambulance supplemental payment programs have been scrutinized by CMS or have been under review by the Office of Inspector General (OIG). In July 2023, the OIG indicated they would be conducting audits of select programs to determine if the participating providers complied with Federal and State requirements.
On August 17, 2022, CMS issued a Center for Medicaid and CHIP Services (CMCS) Informational Bulletin (CIB) about the applicable federal cost principles for GEMT programs. The CIB reported on major provisions of existing GEMT programs, including treatment of fire costs.
Prior to the release of that CIB, costs associated with any personnel dispatched for emergency medical services (EMS) services, regardless of their position – firefighter, emergency medical technician (EMT) – and their associated vehicle, could be considered EMS because they were dispatched for an EMS incident.
However, based on the guidance in the CIB, any personnel dispatched for an EMS incident but who are not a licensed or certified emergency medical technician and did not perform Medicaid covered services on location should be considered fire costs. Prior to this guidance, providers’ supplemental payments may be overstated as fire costs defined by CMS may not be identified and removed from the supplemental payment calculation.
Many states Myers and Stauffer works with have taken steps to mitigate the effect of the CIB and known CMS scrutiny on their programs thus helping reduce the risk of recoupment.
How Myers and Stauffer Can Help
With our extensive experience with and knowledge of the ambulance supplemental payment programs, we provide targeted solutions to help states navigate and optimize existing or developing programs. Our services include:
- Development of managed care-directed payment programs, including help obtaining approval from the CMS of the required 438.6(c) preprint.
- Supplemental payment program set-up, including writing of state plans and administrative rules, and development of cost reports.
- Preparation of calculation models to evaluate options for provider tax program design, including the taxable unit (e.g., revenue, transports), tax rates and tiers, and included and exempted providers.
- Calculation of supplemental payment amounts for affected providers and help with supplemental payment timing and payment mechanics in fee-for-service and managed care.
- Development of statistical models needed to demonstrate a tax program that meets the criteria for a waiver of the federal broad-based and uniformity requirements and also complies with the hold-harmless safe-harbor threshold.
- Assistance with provider tax implementation, including communications with providers, development of operational procedures for levying and collecting the tax, tracking of payment compliance, and support of the state in responding to provider appeals.
- Calculation of cost or average commercial rate (ACR) upper payment limits based on cost reports or ACR data.
- Assistance with the collection and tracking of IGTs for public provider supplemental payments.
- Audits of the GEMT program cost reports as required by CMS annually.
- Audits of the data used for ambulance tax programs.
- Consulting on compliance for both fee-for-service and managed care Medicaid GEMT programs, including directed payment arrangements.
- Monitoring of provider changes to ensure proper assessment of new providers and appropriate treatment of other provider changes (closures, changes in ownership, etc.).
- Participation in meetings and work group discussions with Medicaid agency staff and stakeholders, such as providers and their representatives.
Whether you have an existing program or are pursuing a supplemental payment program for ambulance services, we are here to support you. We can help your agency with audit work and program development to ensure compliance with CMS requirements. Our aim is to become an extension of your team. We will provide the project management, close coordination, and exacting execution you need, all backed by the knowledge you want the skill you require. Visit our general Transportation page for a list of more services we offer, and if you would like more information about how Myers and Stauffer can support, please contact one of our contributors listed below.
For More Information
| Bob Hicks, CPA
Member PH 816.945.5321
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