Five Questions With: Asbel Montes Talks Cost Data at Pinnacle

Asbel Montes is managing partner at Solutions Group Counseling, a company created seven years ago to empower EMS providers to collect their charges from payers rather than their patients. The company creates solutions designed to provide clarity on reimbursement trends.

Along with Kim Godden, vice president of legal, government relations, and corporate compliance at Illinois’ Superior Ambulance Service, Montes will be presenting “Cost Reporting Chaos and Consternations for Fire and EMS” August 11 at the Pinnacle EMS leadership conference in Phoenix.

The presentation will address issues surrounding the Centers for Medicare and Medicaid Services’ efforts to develop a process for collecting data on the cost of ambulance services.

Also of concern is the No Surprises Act (NSA), passed by Congress at the end of 2020, which prohibits air ambulance providers from billing patients more than the in-network cost under the patients’ insurance. An advisory committee under the direction of the Secretary of Health and Human Services is required to study the issue within the ground ambulance industry and make a recommendation to Congress.

In this Five Questions With, Montes discusses the impact on EMS of both endeavors going forward.

Pinnacle will be held August 9–13. Learn more at https://pinnacle-ems.com/.

EMS World: Why did CMS take the approach it did in seeking ambulance cost data?

Montes: The Bipartisan Budget Act of 2018 had a provision that required CMS to develop a data collection system for ground ambulance providers and suppliers. The law specifically stated that effective January 1, 2020 and continuing through 2024, CMS must collect information on cost, utilization, revenue, and other service characteristics in accordance with the Medicare ground ambulance data collection instrument for a continuous 12-month period. Based upon this direction, CMS hired the RAND Corp. to work on the data collection tool. After numerous stakeholder meetings, CMS released the prototype we see today on what the data collection will be. It should be noted that the effective date has been delayed until January 1, 2022. 

What are the origins and goals of the project?

The passage of the BBA of 2018 in regards to the ground ambulance data collection system was a requisite to the five-year extension for the urban, rural, and super-rural ambulance extenders. The information collected will be used to evaluate the reported costs by the ground ambulance providers and suppliers and how they correlate to the payment rates under the Medicare Part B Ambulance Fee Schedule.

How should systems prepare to measure what they need? 

There are 12 components to the cost data collection tool: 

• General survey questions such as company name, address, and national provider identification;
• Organizational characteristics;
• Service area;
• Emergency response time;
• Ground ambulance service volume;
• Service mix;
• Labor costs;
• Facilities costs;
• Vehicle costs;
• Equipment, consumables, and supplies;
• Other costs not already identified;
• Revenues from payers and other alternative sources.

Ground ambulance providers should ensure they have access to appropriate data sources and systems for materials management, payroll, accounts payable, revenue cycle, and computer-aided dispatch. Providers also should work with shared services departments to ensure appropriate allocations to ground ambulance transportation, such as vehicle maintenance, insurance, and other costs that may be shared among divisions not related to ground ambulance transportation. This information will be needed to ensure the accuracy of the ambulance cost data collection tool. 

How does this all present an opportunity to advance the EMS profession?

For years our industry has been advocating for adequate reimbursement from Medicare, Medicaid, and other third-party payers. Additionally, since 2009 alternative payment models have been explored in finite markets throughout the country. The lack of uniform data and understanding the cost of providing services in an objective, aggregate format by geographical area, organizational type, and other factors have inhibited the ability to make significant headway on outlier payment reimbursement, mobile healthcare, and community paramedicine initiatives, as well as quality payment initiatives. This data collection project, if successful, will be a first step in more meaningful payment reform for the ground ambulance industry. 

With respect to the No Surprises Act, what role does cost data play in it, and what could affected providers do to prepare for it? 

In this current version of the NSA, cost data is very impactful on how the independent dispute resolution entity will look at the qualifying payment amount and the ability for the air or ground ambulance provider and supplier to make their case on cost versus adequate and reasonable payment by the payer. Even though the ground ambulance industry was remanded to an advisory committee to study the impact of surprise billing, the committee will be looking at all elements of ground ambulances, from utilization to cost to reimbursement and the state and local regulatory environment. This information will be needed to make informed recommendations to Congress and key committees. 

Carol Brzozowski is a freelance journalist and former daily newspaper reporter based in South Florida. Her work has been published in more than 200 media outlets.