The American Ambulance Association (AAA) has learned that the Centers for Medicare and Medicaid Services (CMS) has started to send notices to ground ambulance providers that missed their deadline to submit cost data under the Medicare Ground Ambulance Data Collection System (GADCS). The notice indicates that these providers will be subject to a 10% reduction in their Medicare payments for a full calendar year unless they take certain remedial steps. The good news is that CMS is offering providers that failed to submit their cost data in a timely manner a grace period in which to submit this information and avoid the future payment reduction.
Relevant Background
Section 50203(b) of the Bipartisan Budget Act of 2018 mandated that CMS develop a data collection system to collect cost, revenue, utilization, and other information from ground ambulance organizations. This data collection system came to be known as the “Medicare Ground Ambulance Data Collection System” (abbreviated as “GADCS”). Initially, CMS planned to divide all Medicare-enrolled ground ambulance organizations into 4 classes, referred to as “Year 1 Participants,” “Year 2 Participants,” etc. Year 1 participants were initially supposed to report their cost data over a 12-month continuous period that began on either: (1) January 1, 2020 (calendar year reporters) or (2) the first date of their fiscal year that began during calendar year 2020 (fiscal year reporters). Year 1 Participants would then have 5 months from the end of their data collection period to submit their reports to CMS through its online portal. This cycle would then repeat itself in subsequent years for Year 2-4 participants.
However, the initial timeline for data collection was modified due to the COVID-19 Public Health Emergency. Under the revised timeline, Year 1 and 2 Participants would be required to collect data over the 2022 calendar year or their fiscal year that began in 2022, and report that data within five (5) months of the end of their collection period.
The recent CMS notifications are being sent to Year 1 and Year 2 ground ambulance providers who elected to report their data using the 2022 calendar year. These providers were required to submit their cost data through the CMS online portal no later than May 31, 2023. The notices indicate that, as of April 17, 2024, CMS has yet to receive cost data from the organization.
Ground ambulance organizations can check all four selection lists on the CMS GADCS website. We recommend searching by your NPI(s), not your organization’s name or address.
Contents of the Notice
The notice indicates that, due to the organization’s failure to submit its cost data in a timely manner, CMS is imposing a 10% payment reduction on Medicare payments. Under law, this payment reduction must be imposed over a future calendar year. However, CMS is not indicating which calendar year that might be (i.e., 2025, 2026, etc.). Rather, CMS is indicating that if the organization remains subject to the 10% reduction, it will receive a subsequent notice from CMS detailing when that payment reduction will begin.
The notice then outlines several steps that the organization must take to avoid this payment reduction. Specifically, CMS is indicating that the organization must:
- Within 30 days of receipt of the letter, enter the GADCS online portal (https://portal.cms.gov) to register for an account AND link that account to the organization’s National Provider Identifier (NPI);
- Within 60 days of receipt of the letter, submit its cost data through the online portal. CMS is reminding organizations that only a GADCS user with the “data submitter” role can enter this information;
- Within that same 60 days of receipt of the letter, have a GADCS user with the “data certifier” role review and certify this organization’s data submission.
What this Means for Your Organization?
If your organization was selected as either a Year 1 or 2 Participant AND you elected to report your data based on the 2022 calendar year, these notices may be applicable to your organization. If you submitted your data within that timeframe, no further action is required. If you failed to submit your cost data within that required timeframe, this notice indicates that it is not too late to avoid the 10% payment reduction. The AAA strongly encourages you to try to submit your data within the next 60 days. The AAA is committed to helping our members through this process. For further assistance, please reach out to us at: hello@ambulance.org.
