Tenth of a Mile Billing - the Sequel

Got a free moment? You still have a few days to comment on the proposed rules published by CMS last month that will likely negatively impact ambulance service revenues in coming years.

In short, last month, CMS resurrected the idea of requiring tenth of a mile billing for ambulance transports. About a year ago, CMS issued a transmittal to that would have required tenth of a mile billing, but that transmittal was later rescinded after there were objections that this change should go through a rulemaking process. Last month, CMS started that rulemaking process by publishing this proposed change along with a couple others that will impact ambulance services. Some estimate that this change will save from $45 million to $80 million per year. This savings comes at the expense of the ambulance industry, but isn't that the only way to save money – not spend it?

The second proposal would allow the Ambulance Fee Schedule (AFS) to reduce reimbursement rates from one year to the next. Currently, the AFS increases annually through the Ambulance Inflation Factor (AIF) calculated with the consumer price index. However, the current formula does not allow for a negative AIF. However, the Healthcare Reform legislation calls for a "MultiFactor Productivity" (MPF) adjustment. The MPF assumes that new technology makes provision of healthcare more efficient – so it should cost less. The proposed rule would subtract the MPF from the AIF to derive a final update percentage for the fee schedule, and the update could be a negative percentage – thereby reducing reimbursement levels.

You have until midnight August 24 to submit comments to CMS regarding the proposed rules. Our friends at Page, Wolfberg, and Wirth have developed a number of materials regarding this matter. Click here to access the PWW page on how to submit comments.