In mid-February 2019, the Centers for Medicare and Medicaid Services (“CMS”), Innovation Center and the Department for Health and Human Services (“HHS”) announced a ground-breaking payment and medical services initiative for ambulance providers called “Emergency Triage, Treat and Transport” (the “ET3”). This new model is the first step in allowing providers of Emergency Medical Services to finally “take off the gloves” to fully utilize both their medical skills and unique patient knowledge to implement a more efficient and effective care model.

Although the current fee-for-service model creates an incentive for all Medicare beneficiaries to be transported to a hospital in emergency situations, even when alternative medical treatments are most appropriate, ET3 will now afford ambulance providers the option to implement two alternative models of medical treatment as follows: 1) provide treatment collaboratively with a health care practitioner who is on scene or through telehealth; and/or 2) transport the Medicare beneficiary to an alternative medical provider such as a primary care physician or clinic. Ambulance providers will be required to apply for admission into the program which will run for five years beginning in 2020. CMS plans to cover 30% of its Medicare participants in this program.

The ET3 model aims to help alleviate overburdened emergency dispatchers by encouraging the creation and utilization of medical triage hotlines for low acuity 911 calls, freeing up resources and personnel for more critical incidents. Funding will be available for up to 40 two-year cooperative agreements for medical triage hotlines, and the application for funding will be made available in the Fall of 2019.

Recognizing the increased work-load that may be initially required to streamline the process of providing proactive emergency medical services to a growing Medicare population, ambulance providers who are selected will be able to earn up to a 5% payment adjustment in the latter part of the program based on defined quality measures benchmarks. Ambulance providers will still be reimbursed at the normal transport rates for Medicare beneficiaries and participating healthcare practitioners and alternative medical providers will also be reimbursed at normal rates. Eventually, CMS’ goal is for ET3 to be implemented across other payor sources, including state-level Medicaid programs. Providers who participate in ET3 will receive additional payments for the services they provide.

While many can speculate as to the potential long-term impact of ET3, perhaps the greatest and most immediate impact will be the ability of ambulance providers teaming with health care practitioners to identify, analyze and determine the best level of appropriate care for beneficiaries before they step foot into a hospital. This collaborative effort will lead to a decrease in unnecessary emergency department and hospital utilizations and lower costs for beneficiaries. Also, communities will be able to ensure that Medicare beneficiaries who are “frequent fliers” for minor medical issues can be treated and released on the scene or diverted to the most appropriate level of care. By ensuring that these “frequent fliers” are going to the medical provider that can best assist them, instead of always going to the local emergency department, communities can slowly, but steadily, see an increase in the health of their elderly population, but also a decrease in unnecessary utilization of limited ambulance resources.

While participation in this program could result in an initial increase of utilization of emergency medical services, its purpose is designed to respond to a growing concern within the medical community about how to best assist Medicare beneficiaries – who often experience the most significant and critical comorbidities. Ambulance providers who participate in this program should be aware of the potential short-term risks – increased call volume and increased time with patients and transports which can limit the number of in-service and available units. However, new and innovative programs have to be tried and tested to combat an ever-changing medical landscape, and ET3 will be able to help spearhead long-term adjustments in improving emergency medical services.

-William J. George is a Senior Attorney at McBrayer law and is located in the firm’s Lexington office.