The Honorable Brian Dempsey, Chairman
House Committee on Ways and Means
The Honorable Stephen Brewer, Chairman
Senate Committee on Ways and Means
State House, Boston

Dear Chairman Dempsey, Chairman Brewer, and Members of the Committees,

On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association respectfully requests that a provision be included in the Ways and Means Committee version of the final fiscal 2011 supplemental budget bill filed by the Governor on August 25 (House 3695) to protect municipalities against disruption to the current system of payment for local emergency ambulance services or underpayment of fees they are entitled to receive.

New research shows that access to high-quality ambulance services and timely access to emergency medical care saves lives and improves outcomes for accident victims and patients. Local ambulance service providers require continued access to a stable and adequate revenue stream in order to maintain the current high level of services provided to Massachusetts residents.

The amendment that we support to Chapter 176D of the General Laws would prohibit the practice of “pay the patient” for emergency ambulance services and clarify that cities and towns have the authority to set reasonable fees for these services. The amendment would avoid the establishment of an inefficient and costly payment system through which cities and towns would be required to collect from patients any payments from insurance companies for emergency ambulance services. Presently, insurance companies make payments directly to the ambulance service provider. The amendment would also clarify that the emergency ambulance fee is set by the municipality, under the strict limitations of the state’s Constitution on local fees.

The amendment to Chapter 176D is similar to Section 31 of House 5028, a fiscal 2010 supplemental budget bill that was approved in the House and Senate last year. Section 31 was returned by the Governor with a recommendation to add three subsections. The amendment we support includes subsections d and e and a changed version of subsection c. We believe that the changes improve the original proposal and respond to the Governor’s concerns.

The enclosed language has two key provisions intended to protect a payment system for emergency ambulance services that is fair and efficient.

First, the proposed amendment would prevent the practice of “pay the patient,” by which patients would be paid directly by their insurance carrier with the onus on the patient to pay the municipality for the emergency transport expense. “Pay the patient” is a practice that would force cities and towns to pursue their own residents, as well as out-of-state residents, to recoup thousands of dollars in ambulance expenses. Receiving a check directly would be a confusing, non-familiar practice for most people, and there would be a high likelihood for misunderstanding.

In Forsyth County, North Carolina, for example, where an insurance carrier has implemented this practice, estimates are that the county is missing about $400,000 in ambulance payments and has incurred additional costs associated with trying to track down such payments. While municipally owned and operated ambulances that bill for their own services are not impacted by this practice, 19 of the 25 largest communities in Massachusetts have contracts with private ambulance companies and therefore are not protected.

Second, the amendment would allow municipalities to set a fair rate for ambulance services. Geography and payer mix make every community different in terms of emergency medical service needs. For example, it is much more expensive to transport a patient in Nantucket than it is in a densely populated community located near multiple hospitals. Similarly, the payer mix of insured and uninsured patients is drastically different in a working-class, urban setting than it is in a more affluent suburban setting. Thus, communities are in the best position to set their own rates for emergency medical response. Municipal officials are held accountable to the taxpayers, and therefore set realistic rates that match the actual cost of ambulance services.

Emergency medical service is quite different from non-emergency transportation. Insurance companies should have the ability to set rates with private ambulance companies for non-emergency transports, but we believe it would be detrimental for municipalities and taxpayers to receive inadequate reimbursements caused by either direct payment to patients or rates that are too low. After taking into account the payer mix of Medicare, Medicaid, privately insured, and uninsured patients, the average ambulance trip for a privately insured patient may cost more than three times the Medicare reimbursement amount.

We believe this amendment would allow cities and towns to set a fair and reasonable fee for ambulance services and to promptly and efficiently receive payment of that fee. We urge you to include this language in H. 3695 when you report the bill out of your committee.

Thank you for your interest in this matter. If you have any questions or desire further information, please do not hesitate to have your office contact MMA Deputy Legislative Director John Robertson at (617) 426-7272 at any time.

Sincerely,
Geoffrey C. Beckwith
Executive Director, MMA

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