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PWW|AG Warns MedPAC’s Selective Data Edits Could Undermine Ambulance Agency Funding

by EMS|MC | May 18, 2025

(Mechanicsburg, PA) – By Doug Wolfberg, Esq. – EMS 1

In December 2024, CMS released the first report on the Ground Ambulance Data Collection System (GADCS). This made news in ambulance circles in early 2025. However, something that happened much more quietly in March is likely to have a greater impact on ambulance services nationwide: the actions of a little-known entity called MedPAC — the Medicare Payment Advisory Commission. MedPAC’s twisting of the GADCS data is likely to minimize any increases to Medicare Ambulance Fee Schedule rates for the foreseeable future.

MedPAC is comprised of 17 appointed commissioners, supported by a staff, and bills itself as a nonpartisan, “independent congressional agency to advise Congress on issues affecting the Medicare program.” Among its other responsibilities, MedPAC advises Congress on payments to providers under Medicare Part B, which, of course, includes ambulance services. Part B rates also serve as the basis for payments to noncontracted ambulance services under Medicare Part C (Medicare Advantage).With Medicare being the most significant portion of the payer mix for most ambulance services, what MedPAC does has a profound impact on the economic well-being and sustainability of ambulance services throughout California, and nationwide.

After the GADCS report came out, many in the industry (including yours truly) did deep dives on its findings. (In fact, in January, PWW held a comprehensive webinar on the report. After all, this was the first nationwide, across-the-board study of ambulance costs that incorporated all provider types — private for-profit, public, hospital-based and non-profit. Another Federal agency, the Government Accountability Office (GAO), released ambulance cost studies in 2007 and 2012, but in both reports, GAO excluded data from “ambulance providers that shared operational costs with other services, such as those provided by fire departments,” hospitals and others. In the GAO’s opinion, cost data from entities that provide ambulance services along with other services are “inconsistent” and “unreliable.” Apparently, the GAO didn’t care about the fact that EMS is not one-size fits all and is provided by different entity types across the country.

So, it was quite meaningful when CMS released the first GADCS report — prepared by its contractor, the Rand Corporation — in December. The report showed that costs for all ambulance provider types — public, private and nonprofit — greatly exceeded the fee-for-service revenues. Medicare rates, in particular, were woefully insufficient to cover the costs of providing ambulance services for all provider types.

Click here to read more about the Excluded Ambulance Cost Data. 

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