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CMS to Terminate Emergency Triage, Treat, and Transport Model
June 30, 2023 - Baltimore, MD - The Centers for Medicare & Medicaid Services (CMS) yesterday announced the early termination of the Emergency Triage, Treat, and Transport (ET3) Model effective December 31, 2023 – two years before the originally published end date.
ET3 provides greater flexibility to EMS providers to address emergency health care needs of Medicare Fee-for-Service (FFS) beneficiaries, once a 911 call is placed. Under ET3, CMS paid participants to transport patients to an alternative destination partner, such as a primary care office, urgent care clinic, or a community mental health center (CMHC), or to initiate and facilitate treatment in place with a qualified health care partner, either at the scene of the 911 emergency response or via telehealth. The goal of ET3 was to allow beneficiaries to access the most appropriate emergency services at the right time and place, improving quality and lowering costs by reducing avoidable transports to the ED and unnecessary hospitalizations following those transports.
According to a memo published by CME, the early termination of ET3 was “…based on a number of factors, including the current number of interventions. Current and projected number of interventions are lower than the number anticipated when the Model was designed.”
But according to Garth Gemar, Medical Director at the Phoenix Fire Department, this lack of use may be due to bureaucratic restrictions.
“I think what CMS didn't realize is that a lot of why agencies didn't take part in the program was the bureaucratic red tape that they put in front of agencies,” Gemar explains.
Many EMS providers found the release of this memo to be concerning. Hanan Cohen, Corporate Director of Mobile Healthcare at Empress EMS / PatientCare EMS Solutions in New York, had previously implemented Empress’ ET3 program. He found the release of this memo to be disappointing and feels concerned about the damage it could cause to the future of these types of programs.
“The biggest setback is the leading payer who was kind of, you know, the champion of the program, is stepping back to the point where a lot of agencies are finally starting to get more and more traction with other individual payers,” Cohen says. “The question is when, you know, the federal agency that spearheaded the program steps back does that give pause for others to do the same? And not necessarily because of outcome issues, but just because of the structure. If the biggest program is stepping back, why should we even bother anymore? And I think that's a danger with as many players as there are in the country and at a point in time where people are just beginning to see some traction from them.”
And outside of this setback, the early termination of this program could have detrimental effects on the patient side, as well.
While the memo does not indicate key changes that removing this model would cause, it does state that the removal of this model will not impact “…the ability to bill for ET3 interventions with a date of service through December 31, 2023, or the ability to receive performance-based payments.” But according to Gemar, this may indicate future challenges with billing for these types of interventions.
“The devil's kind of in the details if they’re going to keep those billable codes or if the whole program to include the ability to bill for the ALS assessment is going to go away, because if that goes away, there'll be no impetus whatsoever to maintain alternative destination, alternative transportation, and field telehealth programs…so it's it could be just fine if all this represents is a deregulation, but this could be just going back to the dinosaur age if they take their billable codes with them,” Gemar says. “It says explicitly you'll be able to bill for ET3 interventions through December 31st with the implication that after that it goes away you know just the wording of that I think kind of they showed their cards here that they're going to take the codes away. So, I just think that this is, therefore, quite a potential step backward.”
Cohen agrees, explaining that the removal of this program could lead to financial confusion.
“It’s certainly not a perfect program, but it’s giving our patients options to be more proactive in their healthcare at a lower cost and in a much safer environment,” Cohen says. “I think as far as coding goes, within our program, not everybody was accepting the modifiers we’ve been billing some insurers just under A0998 because they understand it more…so I think certainly it can cause some confusion.”
While little information has been released regarding the termination of this program, Cohen believes more time is needed to really see the benefits of the ET3 program.
“The challenges we’re looking to overcome are not things that are going to be solved in one or even two years, or even five years which was, you know, a tight time frame for moving an entire EMS system in another direction,” he explains. “So, my takeaways are that it’s the right thing. We need to find another way of moving forward with it. And for anybody that’s doing it, please find ways to touch any patient population you can under any other payer, and just don’t walk away from it. This is the future. We all know it's a setback…so let's all get together and decide how you can make this move forward within the entire US system.
In a statement provided to EMS World, Liz Fowler, PhD, JD, CMS Deputy Administrator and Director of the CMS Innovation Center, commented:
“CMS is committed to transforming the health care system so that all people with Medicare have access to timely and high-quality care. As part of the CMS Innovation Center’s portfolio, the agency tested the Emergency Triage, Treat, and Transport (ET3) Model—an opportunity for our country’s first responders to participate in a model test to broaden the array of services and care they provide. We are grateful for the work they do every day, and we appreciate their participation in the model test.
“After careful review, CMS has made the decision to end the ET3 Model ahead of schedule, on December 31, 2023. The lower than expected model participation levels contributed to a low number of interventions and as a result, CMS was not able to adequately evaluate the model. In addition, administrative costs associated with maintaining the model exceed any potential cost savings.
“All Innovation Center models, including the ET3 Model, provide valuable impacts and lessons learned and contribute meaningfully toward health system transformation. The Innovation Center continues to explore potential opportunities to support the Emergency Medical Services (EMS) community.”
Comments
The premature termination of the ETC3 program by CMS makes no sense to me, especially, as healthcare, across the board, is dealing with a 20% loss of providers and patients continue to deal with access to healthcare in a significant way, because of this loss of providers.
—Michael Wilcox, MD