August 15, 2007
TO: AAA Membership
FROM: Tristan North
AAA Senior Vice President for Government Affairs
RE: Comments on Beneficiary Signature Requirement Proposed Rule
Yesterday, the AAA submitted its comment letter to the Centers for Medicare and Medicaid Services (CMS) on the "Proposed Revisions to the Payment Policies of Ambulance Services under the Ambulance Fee Schedule for CY 2008". The proposed rule is intended to create a specific exception to the beneficiary signature requirement for emergency ambulance services. However, the AAA believes very strongly that the proposed rule would in fact have the unintended effect of increasing the administrative and compliance burden on ambulance service providers and suppliers and on hospitals. In our comment letter we therefore urge CMS to abandon this approach and to instead eliminate entirely the beneficiary signature requirement for all ambulance services.
The AAA has developed a sample letter which is based on the AAA comment letter and posted it on the AAA website. We encourage all AAA members to use the sample letter as the foundation for your own comment letter to CMS on the proposed rule. The more comment letters that CMS receives requesting the elimination of the beneficiary signature requirement the more likely CMS is to act on the request. Please therefore take the time to do the following:
1) Download the sample AAA comment letter entitled "Beneficiary Signature Requirement Sample Comment Letter" located in the "On Capitol Hill" box on the AAA homepage atwww.the-aaa.org.
2) Personalize the letter to your operation and include specific examples of the burden that obtaining a signature has on your resources.
3) Submit the letter by August 31, 2007 to CMS either through their website or by mail. To submit your letter:
a) Electronically Ï Submit comments towww.cms.hhs.gov/erulemaking. Follow the instructions and provide comments on CMS-1385-P.
b) Mail Ï Submit an original copy of the letter and two copies t
Centers for Medicare and Medicaid Services
Department of Health and Human Services
P.O. Box 8018
Baltimore, MD 21244-8018
4) E-mail me email@example.com to notify me that you have submitted a letter.
In addition to addressing the beneficiary signature requirement, the proposed rule would eliminate the requirement that annual updates to the Ambulance Inflation Factor be published in the Federal Register. Instead, CMS would release of the Ambulance Inflation Factor through instruction and on the CMS website. The AAA supports this change as it would allow CMS to publish the official Ambulance Inflation Factor earlier in the year.