Medicaid Supplemental Payment Programs for EMS Providers

The program will begin with eligible services provided on and after January 1, 2023.

A timeline has not been released for the tax assessment for the private and nonprofit providers. Please expect an announcement in the coming months. If it is a Medicaid trip (even as a secondary payer), it will qualify as counting towards the GEMT program on the public provider side.

The final cost report's availability depends on state plan approval from CMS. However, we plan on conducting training using draft versions with the understanding that some elements could change.

The act defines a public provider as any ambulance service provider owned by any municipality or group of municipalities, regardless of whether the ambulance service provider is organized as a nonprofit corporation. To be eligible for the supplemental payment, providers must meet the following criteria:

• Provide ground emergency transportation services to Wisconsin Medicaid members.
• Be enrolled as a Wisconsin Medicaid provider for the period being claimed.
• Be classified as a government organization under federal law.

All costs associated with Medicaid patient transports qualify for this program (even if they have private insurance or Medicare with Medicaid as the second payer). On the public providers' side, all Medicaid trips will qualify for this program.

No, this is strictly a benefit to help emergency medical services (EMS) to have what they need to transport Medicaid patients. The state will pass through eligible additional federal funding to providers.

We are proposing a state plan that is as inclusive as possible, including volunteers and non-profits; however, complete eligibility is subject to CMS approval.

While we understand through initial conversations with partners that career departments are likely to have a higher cost per trip, we anticipate that volunteer departments will still be eligible for additional funding as the cost per trip is likely higher than current Medicaid reimbursement.

We know that finding volunteers to staff departments is a nationwide issue. This additional funding has helped legacy volunteer departments hire their first staff in other states.

PCG will provide a file that shows an overview of the cost reporting schedules in a separate document.

Any ARPA funds used for the dates of service of the cost report are netted out and treated like any other federal funds or grants. It's based on the date the funds are expended.

The SPA process will be pursued as a single SPA for the whole state as the program requirements will be the same regardless of provider location. The cost report used in the program will ultimately arrive at a cost per transport figure based on the unique costs of each provider, accounting for the different operating structures of each agency.

The costs included in the cost report should be the actual expenditures incurred by the agency in providing medical transports during the fiscal year. Direct costs are those that are directly attributable, defined as costs 100% associated with delivering of EMS services. Any costs associated with fire are considered 100% non-EMS costs. A methodology is currently being developed for instances where costs need to be allocated between fire and EMS. The cost report will also include a component for administrative and overhead costs that can be allocated to the EMS operations. The cost report would utilize accrual-based accounting, meaning it's based on dates of service, not dates of payment.

By nature of the data needed, the report may fall back to the department in conjunction with Controller’s offices and village and town clerks. PCG intends to ensure all providers have what they need including training, resources, support, and web-based solutions to be able to complete the report.

In other states, billing vendors have worked with providers to help facilitate report completion.

Cost per call is based on allowable expenditures for the fiscal year. Medicaid revenues will be netted out following the calculation to arrive at allowable costs – only Medicaid fee-for-service revenues will be considered. None of the revenues from other payers will be netted out or factored into the cost report.

PCG’s goal is to make the cost report as user-friendly as possible, including streamlined calculations through an interactive web-based portal. A web-based training will be shared on this site after we receive CMS approval of the final cost report.

In addition, a series of in-person regional training sessions will be held in the late summer and fall of 2023 on how to complete the cost report.

DHS and PCG are also available to provide technical assistance upon request.

This is tied to the state plan approval. We will have a template that was included with the state plan submission per CMS requirements. In recent programs and approvals, PCG found that some of the components in the cost report are the final details to be worked out in the state plan negotiation.

No, each provider’s situation is unique. Current nationwide trends suggest that Medicaid reimbursement represents about 25% of the actual cost of emergency ambulance services. Wisconsin has aggressively raised Medicaid fee-for-service rates over the last few years, so until we complete the cost report we will not know where we fall compared to the nationwide average.

Iowa is the only state that allows volunteer organizations to participate. We have considered using some of that language in our state plan proposal to make the program as open as possible.

Right now, we encourage departments to watch for upcoming meetings where DHS and PCG will deliver breaking news and program updates. We will make frequent contact to keep partners updated on progress.

You can treat it as 2024 revenue – funding will be distributed to the account currently registered to your tax ID. This is not grant funding. This is money for services provided and can be spent as the entity sees fit.

Medicaid payment represents payment in full for Medicaid members. This funding should not get allocated back to patient accounts. This is general funding for the service provider to support operations.

Federal Medicaid Assistance Percentage (FMAP) is the approximate number that DHS receives on each claim where we are eligible for federal dollars for medical procedures. The example indicates an FMAP of 58.99%, meaning that out of every $100 the state receives $58.99 from the federal government and then uses state general purpose revenue to fill in the difference. That number fluctuates based on the economic performance of Wisconsin. We plan on performing outreach and training to entities on how the FMAP works, how it changes, and where you can find the current rate.

Correct, and it would not be counted as part of their commission on the payment. This program doesn’t provide claim-specific payments. It is supplemental payments to backfill the cost of operating EMS programs. Defer to the contract with your billing company on how that works and where you would want to put the supplemental funds. To clarify, if your billing company collects a fee based on revenue, they should not collect a fee for this program.

2021 Wisconsin Act 228 creates a supplemental reimbursement under Wisconsin Medicaid to public ambulance service providers by requiring that DHS seek federal approval of a state plan amendment allowing supplemental MA reimbursement through a certified public expenditure (CPE). The act provides supplemental MA reimbursements for public ambulance services, including any ambulance service provider owned by any municipality or group of municipalities, regardless of whether the ambulance service provider is organized as a nonprofit corporation. The voluntary GEMT supplement reimbursement program allows Wisconsin Medicaid participating public ambulance providers to elect to submit an annual cost report and receive additional payments.

PCG has worked with several states to implement similar programs, with program implementation underway in five more. The states where PCG has implemented similar GEMT programs include Maryland, Illinois, Florida, Oregon, Iowa, Colorado, Texas, Oklahoma, Washington, Kentucky, Arkansas, and New York.

PCG has successfully implemented this program in states with a wide variety of providers in larger cities like Miami-Dade, Florida; Baltimore, Maryland; the District of Columbia; and New York City Fire Department to small providers in rural areas across the country.

A CPE is a statutorily recognized Medicaid financing approach by which a governmental entity, including a governmental provider (for example, county hospital, local education agency), incurs an expenditure eligible for federal financial participation (FFP) under the state’s approved Medicaid state plan (§1903(w)(6) of the Social Security Act; 42 CFR 433.51). The governmental entity certifies that the funds expended are public funds used to support the full cost of providing the Medicaid-covered service or the Medicaid program administrative activity. Based on this certification, the state then claims FFP.

CPE-based financing must recognize actual costs incurred. As a result, CMS requires cost reimbursement methodologies for providers using CPEs to document the actual cost of providing the services, typically determined through periodic cost reporting, and reconciliation of any interim payments.