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CMS Moratoria Update

August 05, 2016


As reported by the American Ambulance Association (AAA), on July 29, 2016 the Centers for Medicare and Medicaid Services (CMS) lifted the moratoria on Medicare enrollment for Part B emergency ground ambulance suppliers in all affected geographic areas.  The moratoria still exists, however for Part B non-emergency ground ambulance suppliers, and has been extended for another six months.


The moratoria began in 2013, first affecting Medicare part B ground ambulance suppliers in several Texas counties (Harris, Brazoria, Chambers, Fort Bend, Galveston, Liberty, Montgomery, and Waller).  Following, in February 2014, CMS announced the first of many 6 month extensions to the moratoria and the addition of Philadelphia, Pennsylvania and the surrounding counties (Bucks, Delaware, and Montgomery), as well as the New Jersey counties of Burlington, Camden, and Gloucester.  Since 2014, CMS has extended the moratoria four additional times, the most recent being in February 2016.


The moratoria do not apply to changes in practice location, changes to provider/supplier information (e.g., phone number, address), or changes in ownership, only new enrollment in Medicare Part B. 


When determining if there is a high risk of fraud, waste, and abuse in a particular area, CMS considers qualitative and quantitative factors prior to establishing a moratorium.  They consult with the Office of Inspector General (OIG) within the Department of Health and Human Services (HHS) and the Department of Justice (DOJ).  CMS also considers whether imposing a moratorium will have a negative impact on beneficiary access to care.


CMS made the decision to lift the moratoria for new Part B emergency ambulance suppliers because their evaluation revealed that the majority of risk of fraud, waste, and abuse stems from non-emergency ambulance suppliers.  In addition, CMS determined that the established moratoria were creating potential access to care issues for emergency ambulance services.

 

Moving forward, new emergency ambulance suppliers seeking to enroll with Medicare will be subject to “high risk” screenings prior to enrollment.  Once enrolled, new suppliers will be permitted to bill only for emergency transportation services.  They will not be permitted to bill for any non-emergency services.  The moratoria remain in place for Medicare Part B non-emergency ground ambulance suppliers for all counties currently affected in Texas, Pennsylvania, and New Jersey.


Also, CMS does not indicate how they will identify emergency and non-emergency ground ambulance suppliers for purposes of the new moratoria.  There is a checkbox on the Medicare enrollment application (855b) where applicants can check what type of runs each vehicle provides, however it is possible that any newly-enrolling suppliers in PA, TX and NJ who check "Non-emergency runs" on the 855b will be automatically denied enrollment.  That stated, what will CMS do if a supplier does not check the "Non-emergency runs" box, and instead only checks the "Emergency runs" box, and then subsequently provides and wants to bill for a non-emergency service because it does not meet Medicare's criteria for an emergency transport?  CMS has yet to provide clarity on this issue.


Click here to review the full announcement, which was posted on the Federal Register on August 3, 2016. 

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