• relliott
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CMS Approval of QAF
Q.  Ross, I must have missed the news..... did CMS approve the QAF yet? What's the hold up on that?

A.  The State Plan must first be written by DHCS, and then submitted for approval to CMS.  DHCS estimates that the plan will receive CMS approval sometime in the Spring of 2018.  If true, the QAF becomes effective July 1.
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Ambulance Company granted extension by DHCS for filing SB 523 Report
Second extension of time just granted....

Dear Pamela:
 
We are providing a second extension. Please submit the required transport and gross receipt data by close of business on December 15, 2017. Please note that penalties may be assessed, if the data reports are not submitted to DHCS by this date.
 
Please let us know if you have any additional questions.
 
3uGFP1vItldzuFhEaivcGEMT QAF
CA Department of Health Care Services
 
 
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Ambulance Company granted extension by DHCS for filing SB 523 Report
Hi Ross,
I just rec'd this response from DHCS in regards to my objecting to the limited time given to submit the GEMT data to them.  Can you please pass this on? I don't know if you must contact DHCS directly as I did or this is their unspoken policy.


Dear Pamela:
 
Thank you for following up with us.  No, we do not require any additional forms.  We can provide an extension for your submission deadline.  Please submit the required transport and gross receipt data by close of business on December 1, 2017. Please note that penalties may be assessed, if the data reports are not submitted to DHCS by this date.
 
Thank you again for your message.  Please contact us if you have additional questions.
 
 
3uGFP1vItldzuFhEaivcGEMT QAF
CA Department of Health Care Services
 
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DHCS to Answers SB 523 Questions at CAA Workshop
CAA & EMSAAC Workshop - EMS Economics
Thursday, December 7, 2017
Marines' Memorial Club - San Francisco, CA

Please  join us in San Francisco from 8am-4pm on Thursday, December 7th for an all day workshop to discuss EMS Economics. 
 
This one-day workshop will explore the various funding mechanisms of ambulance services, the true costs and impacts of EMS system enhancements and pass-throughs and how to calculate them, the cost of offload delays, and more.

Additionally, an official from DHCS will be presenting information about the new GEMT-QAF (SB 523) and will be able to answer questions about this new law and how it is being implemented.

Register for the workshop at:  Register Here 
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Question about SB 523 being tax deductible - November 21, 2017
  1. Q.  Is the QAF for 523 tax deductible?
  2. A.  It is a tax, and it will be business expense. It just might be tax deductible.  This is definitely worth bringing to your tax accountant’s attention.

 

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CAA Member Alert sent via email - November 15, 2017

Data Required by SB 523 is Due Today

SB 523 (Hernandez) is the so called "ambulance QAF bill" and it is supposed to increase Medi-Cal payments to emergency medical transport providers - next year.

This California law requires ambulance providers to submit data to the Department of Health Care Services (DHCS) TODAY, November 15, 2017. Failure to submit the data by the deadline could result in a $100/day penalty, which is assessed every day the data is late.

If your company is unable to meet today's data reporting requirements, you are encouraged to contact DHCS via their email in-box, explain your situation, and request an extension of time.  We believe it better to communicate with them now and explain your particular situation rather than wait and be silent.

DHCS has established a website with compliance instructions and more information.

Additionally, the CAA will be holding a workshop on EMS Economics in San Francisco, Dec 7, from 8:00 to 4:00.  We confirmed last night that a representative from DHCS will be participating in the workshop to provide information about SB 523 compliance and answer questions.  Register today.

 

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Email from DHCS to CAA - November 13, 2017

From DHCS:  Good afternoon Chris,  Not sure if we answered your question already.

We are currently collecting data for the total number of emergency medical transports by payer type, including Medi-Cal fee-for-service (FFS) and Medi-Cal managed care ground emergency medical transports, and all other payer types, for the quarter beginning July 1, 2015 through the quarter beginning July 1, 2017. We are also collecting the gross receipts received from the provision of emergency medical transports for FYs 2015-16 and 2016-17.

Transports should be reported based on the date of service when transport was provided. Gross receipts should be reported on a cash basis of accounting.

Please visit and review our GEMT QAF website where you will find additional information and a link to Senate Bill 523. http://www.dhcs.ca.gov/provgovpart/Pages/GEMTQAF.aspx

Thank you for your email. Let us know if you have any additional questions.

 

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Question Regarding Gross Receipts - November 11, 2017
  1. Q.  That the bill language only specifies HCPIC codes for the emergency transport and not the supporting codes, such as mileage and therefore that should not be included in reporting.

 

  1. A.  From member of 911 Ambulance Alliance - The language from the DHCS website: (http://www.dhcs.ca.gov/provgovpart/Pages/GEMTQAF.aspx) is as follows:  “Gross receipts” are defined by statute as “gross payments received as patient care revenue for emergency medical transports, determined on a cash basis of accounting, [and] shall include all payments received as patient care revenue for emergency medical transports billed with billing codes A0429 BLS Emergency, A0427 ALS Emergency, and A0433 ALS2, and any equivalent, predecessor, or successor billing codes [X0030; determined] by [DHCS] and any other ancillary billing codes associated with emergency medical transport[s].

The red text is where the answer can be found. In short, all revenue for transports using those codes, including revenue for ancillary charges (i.e. mileage, O2, night, supplies, etc.) needs to be included.

As for the 2nd issue, providers need to submit their questions to DHCS as soon as possible. GEMTQAF@dhcs.ca.gov

 

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Customer Notification from Zoll - November 10, 2017

A member company forwarded this message that was received earlier in the day:

SB- 523 New California Reporting Requirement for EMS Providers and Suppliers in California

Dear RescueNet Billing Customer,

We have received inquiries from our California RescueNet Billing accounts about a new reporting requirement that was recently passed by the senate. We are working on a report to satisfy the state regulation. Currently, we have contacted the state for further details and clarification before we can complete the report.

Furthermore, in our communication with the state, they suggested that agencies that are not ready to comply with this new requirement can request an extension by sending an e-mail to the following: GEMTQAF@dhcs.ca.gov

We will let you know when the report has been completed and is available for your agency’s use.

Sincerely,  ZOLL RescueNet Billing Development Team

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Complex Billing Question - November 9, 2017
CAA received the following question/commentary via email:

I requested DHCS policy regarding Paramedic Pass Through Billing in a CPRA one week ago. It is not on their radar, however taxable codes, either ALS1 or ALS2, are used and as I read SB523 must be taxed. These same agencies also charge a medical supply fee and/or dispatch fee. I am wondering if it taxable, (they stated not only the three billing codes but any service charge connected to them is subject to the tax. Mileage, oxygen, night charge, supplies and so on.)

The have requested I resubmit my PRA for review by legal counsel, again. If DHCS does tax, fire agencies likely need a Safe Harbor Letter from CMS in regards to who pays the tax and billing/finances charges to avoid inducement crimes.

According to DHCS the "fee", tax, and the required financial data is clearly on a cash basis, not accrual basis. As spelled out in the demand letter. Is this true?  According to DHCS when they say "Gross Receipts" they only mean on the codes subject to "fee" and connected revenue, not your company or agencies gross receipts. They had trouble understanding that in accounting terms for a public agency "gross receipts" typically means all revenue for one program, not for sub financial sections or revenue portions. I told them this is causing panic. They had a flat affect.

 They readily admitted they have answered few e-mail questions sent to the general inquiry box. For some reason I made them nervous and wanted to talk.

The tax is not .051%. They will announce in June 2018 what the tax will be.

When I brought up capitation in simple terms they seemed to understand. I said for fraud prevention reviewing none Medicare/Medi-Cal will be tough. Some providers have base rates in $2,000 to $3,000 range. Problem is not only Medicare restricts the fee but CDCR and WC also peg to Medicare rate. In counties like Imperial, Kings, Lassen 2/3 or more of "private pay" may be capitated rates. They understood this, but provided no information as to how breaking out rates would prevent fraud.

As to Medi-Cal they understood that about 90% of Medi-Cal and 50% of Medi/Medis are managed care and that providers are typically blinded to Medi-Cal status. I did not ask, my question is will the supplement cover these patients or only straight Medi-Cal? County run Medi-Cal risk HMOs can't supplement payments. I skipped another managed care question completely, let them figure it out or not.

 According to DHCS staff the tax is "Gross Receipts" times .051 divided by estimated emergency runs which results in the tax factor. Same formula for 2019. They state in 2020 the tax goes up but I don't see in SB523 or Federal Registry how that is calculated, allowed by law or by regulatory fiat.

Commercial providers should ask for rate increases now if they need to go through city councils or board of supervisors. Public agencies should increase rates asap. This issue is without a taxing factor, loss revenue, how much of a rate increase.

I asked about bad debt or delayed payment. I told them third party liability or WC cases can take months to years. As to revenue they want that reported on cash basis, when paid. I did not get answer about bad debt collections. I don't want to assume (ass u me) so do you report these transports as they happen in your quarterly statement? or when paid?

I told them I did not think most providers could meet the 15th deadline. You are looking at about eight software vendors. Some can generate reports, some cannot.  They said they would make exceptions on case by case basis. I would recommend immediately asking for delay. Local government agencies should send a bill to DHCS for staff time, software, hardware and consulting time under unfunded state mandate. Remember bill early and often.

I see at least 10 ambulance providers DHCS did not contact/are not aware of. DHCS respond to my list request yesterday but it is incomplete, lacks addresses. The first part is non-profit, commercial and Indian providers. It appears to be a copy of CHP's ambulance vehicle count list. The public agency list it appears they called around to LEMSAs or read websites. They missed two fire departments in Los Angeles, UCLA Ronald Reagan Medical Center and UCLA PD....and LA County's own ambulance program. Will review in detail tonight.

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Question Regarding Data Submission and definition of "Paid" transports - November 6, 2017

November 6, 2017

  1. Q.  Submitted To DHCS: One of our member ambulance companies contacted us with a question regarding the GEMT Quality Assurance Fee data collection requirement.

 The member has read the instructions on the GEMTQAF website and read the instructions on the GEMTQAF submission form.  The instructions and definitions on the website and the “instructions” tab on the submission form are consistent.  Yet, the definitions on the “example” tab of the submission form seem to be causing confusion.

 In the list of definitions on the “example” tab, the transports are defined as: “Number of xxxxx emergency medical transports paid by payment type xxxxxx”.

 The instructions and definitions on the website and the “instructions” tab on the submission form seem to require the number of transports performed/conducted.  However, the instructions on the “example” tab seem to require the number of transports that were actually paid.

 Please clarify this inconsistency.  Are ambulance companies required to report the number of transports performed/conducting during the reporting period, or the number of transports that were paid during the reporting period?

Obviously, the number will be different because there is often a lag time in payments being received.

Thank you for your assistance.

 

  1. Received November 13, 2017 from DHCS: Not sure if we answered your question already.  We are currently collecting data for the total number of emergency medical transports by payer type, including Medi-Cal fee-for-service (FFS) and Medi-Cal managed care ground emergency medical transports, and all other payer types, for the quarter beginning July 1, 2015 through the quarter beginning July 1, 2017. We are also collecting the gross receipts received from the provision of emergency medical transports for FYs 2015-16 and 2016-17.

 Transports should be reported based on the date of service when transport was provided. Gross receipts should be reported on a cash basis of accounting.

 Please visit and review our GEMT QAF website where you will find additional information and a link to Senate Bill 523. http://www.dhcs.ca.gov/provgovpart/Pages/GEMTQAF.aspx

 Thank you for your email. Let us know if you have any additional questions.

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Question Regarding Gross Receipts - November 5, 2017
  1. Q.  Submitted to DHCS: Medicare EM Transports and Gross Receipts: is this for just original Medicare or does this included original Medicare AND Medicare Advantage Plans?
  2. A.  Response from DHCS: Thank you for your question.  Our team will look into this and follow up with you.
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CAA Member Alert sent via email - November 2, 2017

Time Sensitive Data Reporting Requirement

SB 523 (Hernandez) is the so called "ambulance QAF bill" and it is suppose to increase Medi-Cal payments to emergency medical transport providers - next year.

This California law requires ambulance providers to submit data to the Department of Health Care Services (DHCS) on November 15, 2017.  Failure to submit the data by the deadline results in a $100/day penalty, which is assessed every day that the data is late.

DHCS has established a website with instructions and more information. Here is the information we have received...

Good morning, this is to notify you of the newly developed webpage specifically for the Ground Emergency Medical Transportation Quality Assurance Fee Program. By using the link, you will find background and deadline information, as well as the data submission form and instructions. We have also established an email in-box for providers to submit any questions or comments. The email address is included in the webpage.  We will notify providers by direct mail and via a Newsflash article on Department's website.

 

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Email from DHCS - October 31, 2017

Good morning, this email is to notify you of the newly developed webpage specifically for the Ground Emergency Medical Transportation Quality Assurance Fee Program. By using the link below, you will find background and deadline information, as well as the data submission form and instructions. We have also established an email in-box for providers to submit any questions or comments. The email address is included in the webpage.

  http://www.dhcs.ca.gov/provgovpart/Pages/GEMTQAF.aspx

Thank you for taking the time to discuss the Program with us last week. As shared, we will notify providers by direct mail and via a Newsflash article on Department’s website. We greatly appreciate your assistance with messaging out Program details and the website to providers directly. This will help to ensure a successful data collection process.

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Notes from Conference Call with CAA and DHCS - October 27, 2017

Participants:

Angel Rodriguez - DHCS; Connie Flores - DHCS; Jacqueline Leto – DHCS

Kim Oreno; Jaison Chand; Steve Grau; Chris Micheli; Fred Sundquist; Alan McNany; Jimmy Pierson; Todd Valeri; Dale Feldhauser

 NOTES:

Connie began with some background. Her division is the fee for service rate development division. Develops outpatient and long term care facility rates. Angel handles rate setting for ambulance. QAF bill gives opportunity to increase rates with rate increase funded via add on determined by upcoming data collection process. The add on amount, once determined, will be posted.  Aiming for 7/1/18 effective date. They are required to submit State Plan Amendment (SPA) by 6/30/18. They hope to submit the SPA by February 1. Privates are not involved in creating the SPA. They will post public notice on dept’s website before the end of the year. There will be a 30 day public comment period because of the rate change and the SPA will be provided. There’s a SPA webpage that lists all proposed upcoming SPAs. DHCS also has to submit an access study report (info included could be # of providers by locality, expenditures, rate comparison, etc) and information on the public comments.

First reporting deadline - $100/day late fee not yet being assessed. Angel and his group are setting up a website, Ground Emergency Medical Transportation page. Info will be posted there, form that they’re asking providers to use, instructions, sample form. They did similar webpage for clinical labs and used that as template. That website will go live in 2 or 3 days. The webpage has been sent off to legal folks for review. November 15th is new deadline – trying to keep everything on track and moving forward. She thinks they’ll be able to take late submissions and won’t be super strict enforcing the late fees at first. They are developing a mailing list of providers who bills for the 3-4 codes that are outlined in the bill. A direct mailer will be sent to them. An email will be sent anytime there is an update. A newsflash will go out on dept website. They are trying to capture as many providers as possible. Kim forwarded CHP list to Chris to forward to DHCS. Need to send names & email addresses of who to include on email blasts. An email inbox has been set up to field questions. Ancillary codes and expenses that are on claims with the 3-4 codes need to be included in the reporting. Dry runs will not get the add on and they don’t need the data. Connie will send a sample of the form to Chris and Chris will distribute.

Potential outcome of public comment – DHCS has to address any concerns from the public and provide evidence to CMS that those concerns have been addressed. Hard to say what they’ll be and what the effect will be.

Meeting concluded at 1:38pm.

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