PHI Health Issues Public Comment on DOT Notice
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1. Request confirmation that DOT has the authority to compel data collection from hospital-based air ambulance services that contract with Part 135 certificated air carriers for aviation services, as indirect air carriers:
As DOT works to finalize committee recommendations, we ask that the DOT clarify its role and its statutory authority to collect data from hospital-based air ambulance services. Based on comments made by DOT in the
2. HHS should specify initial payment in the
After considerable committee member discussion regarding the statutory authority of HHS to require an initial payment for air ambulances, the committee failed to support a recommendation. However, throughout the meeting, much of the discussion included consideration of alignment of recommendations with the No Surprises Act.
The
We also ask that the Tri-Departments acknowledge the silent, but powerful effects of using Medicare rates as a benchmark for in-network contracts. The continued use of Medicare rates as a reference by insurers in network negotiations contributes to a deflated valuation of air ambulance services. Reimbursement from Medicare, Medicaid, and other government payers is more than 40% less than the cost of providing the service. This results in a significant amount of under-compensated care that must be offset. Historical out-of-network payment data is essential to understanding how historical out-of-network commercial insurance reimbursement provides funding that mitigates the under-compensation by government payers. Of the 10-30% of air ambulance patients transported that are commercially insured, it is our experience that only 30% of those patients have plans with network agreements (despite our efforts to improve network participation). To put this in real terms, out of 10 patients transported, less than two may be in-network. Relying on a median of in-network agreements gives disproportionate weight to this very small number of claims and disregards the financial realities that air ambulance services face. To correct this, we urge HHS to consider the median of historical in-and out-of-network payments for air ambulances as a basis for determining an initial payment to air ambulances for reimbursement for emergency medical transport.
Lastly, we urge HHS to be cautious in consideration of existing databases in areas where insufficient data exists. It is our experience that the dominant databases (e.g., HCCI and FairHealth) rely primarily on hospitals and health systems, which may skew consideration of an initial payment towards a level that is sufficient for a subsidized service, but not for a rural, nonsubsidized air ambulance provider.
3. Process:
In response to the questions from some plenary committee members regarding the scope of the AAPBAC charter (and the potential for inclusion of consideration of revision of the Airline Deregulation Act) during the
Sincerely,
Director, Government Affairs & Industry Relations
email: [email protected]
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The notice can be viewed at: https://www.regulations.gov/document/DOT-OST-2018-0206-0027
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