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HomeMy WebLinkAbout18 - Ground Emergency Medical Transport Intergovernmental Transfer Voluntary Participation for Calendar Year 2025Q �EwPpRT CITY OF s NEWPORT BEACH `q44:09 City Council Staff Report January 14, 2025 Agenda Item No. 18 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Jeff Boyles, Fire Chief - 949-644-3101, jboyies@nbfd.net PREPARED BY: Raymund Reyes, Administrative Manager - 949-644-3352, rreyes@nbfd.net TITLE: Ground Emergency Medical Transport Intergovernmental Transfer Voluntary Participation for Calendar Year 2025 ABSTRACT: In 2019, Governor Gavin Newsom signed Assembly Bill No. 1705 (AB 1705) into law, authorizing the replacement of two existing Medi-Cal reimbursement programs with a single program under a new Public Provider GEMT Intergovernmental Transfer (PP-GEMT-IGT) process. This program is voluntary and its success is dependent on the participation of all transporting agencies. The City of Newport Beach participated in the inaugural Calendar Year (CY) 2023 program as well as the CY 2024 program. Total reimbursement (including pending amounts) indicate reimbursement amounts beyond original estimates. The Fire Department is requesting continued participation for CY 2025. RECOMMENDATIONS: a) Determine this action is exempt from the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) and 15060(c)(3) of the CEQA Guidelines because this action will not result in a physical change to the environment, directly or indirectly; and b) Approve the City of Newport Beach's voluntary participation in the Public Provider GEMT Intergovernmental Transfer program per AB 1705 for Calendar Year 2025, and authorize the City Manager to execute the Public Provider Intergovernmental Transfer Program for Ground Emergency Medical Transportation Services Certification Forms and pay all necessary invoices. DISCUSSION: The Medi-Cal program is the State of California's Medicaid program and is administered by the California Department of Health Care Services (DHCS.) Medi-Cal provides qualified California residents with healthcare coverage. This coverage can extend to Emergency Medical Services (EMS), including those provided by the City's Fire Department. Unlike patients with private insurance (or in most cases, Medicare), Medi-Cal patients do not have a co -pay and medical providers like the City must accept Medi-Cal payments as payment in full. 18-1 Ground Emergency Medical Transport Intergovernmental Transfer Voluntary Participation for Calendar Year 2025 January 14, 2025 Page 2 Medi-Cal is partially governed and funded by federal Medicaid provisions. Medi-Cal plan holders account for approximately 10%-15% of all City medical transports and the City is reimbursed for EMS services directly from the State's Medi-Cal program. Medi-Cal has historically paid a capitated base rate of $118.20 per transport since 1999; this is significantly lower than the actual costs for the City to provide transport service. The California Department of Healthcare Services' (DHCS) Quality Assurance Fee (QAF), Ground Emergency Medical Transport (GEMT), and Intergovernmental Transfer (IGT) programs provide additional revenue to help offset the cost of service. Passed in 2019 but not implemented until 2023, AB 1705 implemented a new Medi-Cal Public Provider Intergovernmental Transfer Program (PP-GEMT-IGT) for public ground emergency medical transportation providers. The program replaced the outgoing QAF and GEMT programs and provides additional payments to public providers who transport Medi-Cal patients. IGT remains viable and the City continues to participate in this program. PP-GEMT-IGT is funded by a combination of ambulance transport agency funds and a federal Centers for Medicare and Medicaid Services (CMS) match, called a Federal Financial Participation (FFP.) The State's general funds cannot be utilized for this reimbursement program, so public ambulance providers voluntarily provide the State with the amount needed (roughly $110 million) through an Inter -Governmental Transfer. DHCS then uses the non-federal funds to draw down available matching federal funds and uses the combined sum to pay the add -on amount per eligible Medi-Cal transports. DHCS manages the reimbursement processes and charges an administrative fee of 10% of the non-federal share amount. This add -on amount is currently $946.92, bringing the total add -on amount (including the base rate) to $1,065.12. The City Council previously approved participation for both CY 2023 and CY 2024. Based on amounts received to date and pending amounts forthcoming, the program appears to be successful. Staff requests City Council approval to participate in the CY 2025 program. FISCAL IMPACT: Because DHCS elected to submit payments via an add -on amount, the month or even year in which add -on fees are collected are not necessarily reflective of the time when the transport occurred. Whereas DHCS' IGT program consists of a single payment to the State followed by a single reimbursement back to the City for completed transports in a prior calendar year, PP-GEMT-IGT add -on payments are included with the $118.20 base rate amounts and remitted to the City as part of the normal billing collection process. This can result in a delay between the month that the transport occurred and the receipt of any payments. As a result, pending amounts yet to be collected cumulatively roll forward, and revenues could be reflective of add -on amounts for either year. 18-2 Ground Emergency Medical Transport Intergovernmental Transfer Voluntary Participation for Calendar Year 2025 January 14, 2025 Page 3 PP-GEMT-IGT ADD ON FEES FOR CY 2023, CY 2024 Calendar Payments to Original Add -On Fees Add -on Fees PP-GEMT-IGT Year DHCS (slot Estimated Collected Pending Prospective Program including 10% Revenue through Oct Receipt Total Revenue admin fee) 2024 (through Oct for CY2023, 2024) CY2024 2023 $399,377 $1,181,208 $565,514 $1,728,075 $3,032,787 2024 $390,461 $1,155,655 $739,198 TOTALS: 1 $789,837 $2,336,863 $1,304,712 $1,728,075 "l hIS amount Includes approximately $3,b21 In lettover QAl- reimbursements received from UHGJ during the F'N-CitM I -IG I implementation process. Even so, the program seems to have surpassed original estimates. Add -on fees already collected have exceeded the City's original contribution amounts, with a pending add -on amount owed of $1,728,074.62. Based on the pending amounts yet to be received, revenue estimates may be upwards of $695,923.96 higher than originally anticipated for CY 2023 and CY 2024 combined. DHCS Payments to Date PP-GEMT-IGT Prospective Total Revenue to Date Projected Net Revenue (including pending amounts) $789,837 ** $3,032,787 $2,242,950 "While UHUS has invoiced the Uty for UY 2U23 and UY26124 amounts; agencies have not yet been invoiced any 1 U% administrative fee amounts. To participate as a funding entity for CY 2025, the City must transfer local funds up to an estimated total contribution amount of $364,855, which includes the 10% administrative fee estimate. Based on current DHCS figures, the number of possible transports and the current program reimbursements, the City may expect to receive a total of $1,310,133 from the CY 2025 program, resulting in an approximate net revenue of $945,278. It is important to note that depending on total agency participation, the actual payment amounts due during the year may be higher or lower. DHCS recently published a public notice for the CY 2025 State Plan Amendment (SPA), SPA 25-0002. This SPA includes a proposed add -on reimbursement amount of $1,478.68 for CY 2025 (an increase from $946.92 to $1,360.48.) The SPA is expected to be submitted to CMS in the first quarter of CY 2025. However, approval from CMS is not anticipated until late CY 2025. If approved by CMS, retroactive adjustments reflecting the CY 2025 add -on amount will be applied for the period of January 1, 2025, through December 31, 2025. Retroactive reimbursements would follow the standard process of Medi-Cal Managed Care Plans reconciling payments based on the updated add -on amount. Adjustments will be applied to each eligible GEMT claim processed during the retroactive service period, 18-3 Ground Emergency Medical Transport Intergovernmental Transfer Voluntary Participation for Calendar Year 2025 January 14, 2025 Page 4 once the rates are finalized and approved by CMS. Assuming the amendment passes, the City could be required to process additional payments to the State, but could also see increased add -on revenues in a later fiscal year. The adopted budget includes sufficient funding for the first two quarterly payments due in January and April 2025. Payments will be expensed from the PP-GEMT-IGT account in the Fire Department's EMS Division, 01040404-821010. The two remaining payments in July and October 2025 will be incorporated into the Fiscal Year 2025-26 adopted budget. Anticipated revenues from the CY 2025 program have been incorporated into the current year budget (for amounts estimated to be received prior to June 30, 2025) and the Fiscal Year 2025-26 budget process. ENVIRONMENTAL REVIEW: Staff recommends the City Council find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. NOTICING: The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). ATTACHMENTS: Attachment A — Certification for CY 2025 PP-GEMT-IGT Program Attachment B — Public Notice Re. State Plan Amendment 25-0002 18-4 ATTACHMENT A DEPARTMENT OF HEALTH CARE SERVICES PUBLIC PROVIDER INTERGOVERNMENTAL TRANSFER PROGRAM FOR GROUND EMERGENCY MEDICAL TRANSPORTATION SERVICES CERTIFICATION FORM FOR STATE CALENDAR YEAR 2025 I, the undersigned, hereby declare and certify on behalf of the City of Newport Beach (the "Public Entity") as follows: 1. As a public administrator, a public officer, or other public individual, I am duly authorized to make this certification. 2. ; The Public Entity elects to make this intergovernmental transfer (IGT) to the Department of Health Care Service (DHCS) as a voluntary contribution to the non-federal share (NFS) of Medi-Cal expenditures for purposes of Assembly Bill 1705 (2019) pursuant to Sections 14105.94, 14105.945, 14129, 14129.3, and 14164 of the Welfare and Institutions (W&I) Code. All funds transferred pursuant to this certification qualify for federal financial participation (FFP) pursuant to Section 1903(w) of the Social Security Act and Title 42 of the Code of Federal Regulations, Section 433 Subpart B, and are not derived from impermissible sources such as recycled Medicaid payments, federal money excluded from use as the NFS, impermissible health care -related taxes, or non -bona fide provider - related donations. 3. Voluntary contributions attributable to the period of January 1, 2025, through December 31, 2025, will be made via recurring transfers as indicated on the invoices provided to the Public Entity by DHCS. The voluntary contributions made by the Public Entity may also include fee -for -service (FFS) adjustments related to the calendar year (CY) 2023 and managed care (MC) adjustments related to the CY 2024 rating period's NFS reconciliation as described in paragraph seven below. Please note, the total IGT amount at the bottom of this IGT certification will continue to be itemized on your invoice which is sent to you along with this IGT certification form 45-days in advance of the IGT contribution due date. The Public Entity acknowledges that any transfers made pursuant to this certification during this time period are considered an elective IGT made pursuant to W&I Code sections 14105.945 and 14164, to be used by DHCS, subject to paragraph four herein, exclusively as the source for the NFS of ground emergency medical transport public provider supplemental payments in both Medi-Cal FFS payments and the portion of the risk -based capitation rate to Medi- Cal managed care health plans associated with reimbursement made in accordance with Section 14105.945, subdivision (h)(1) (hereafter, 'the AB 1705 Public Provider Ground Emergency Medical Transportation (PP-GEMT) Program or PP-GEMT Program), and DHCS costs associated with administering the PP- GEMT Program. 4. DHCS may accept this voluntary contribution to the extent it is able to obtain FFP for the PP-GEMT Program as permitted by federal law. In the event DHCS is unable to obtain FFP for the PP-GEMT Program, or the full payments cannot otherwise be made to and retained by eligible public providers, and, therefore, all 18-5 DEPARTMENT OF HEALTH CARE SERVICES PUBLIC PROVIDER INTERGOVERNMENTAL TRANSFER PROGRAM FOR GROUND EMERGENCY MEDICAL TRANSPORTATION SERVICES CERTIFICATION FORM FOR STATE CALENDAR YEAR 2025 or a portion of the transferred amount cannot be used as the NFS of payments, DHCS will notify the Public Entity via e-mail and return the applicable portion of the unused IGT amount. 5. The Public Entity acknowledges that, in accordance with W&I Code section 14105:945, subdivision (h)(2), DHCS shall assess a ten percent (10%) fee on each transfer of public funds to the state to pay for health care coverage and to reimburse DHCS its costs associated with administering the PP-GEMT Program. 6. The Public Entity acknowledges that the IGT is to be used by DHCS for the filing of a claim with the federal government for federal funds and understands that any misrepresentation regarding the IGT may violate federal and state law. 7. The amount voluntarily transferred to DHCS is based on the estimated Medi-Cal FFS and Medi-Cal MC NFS of ground emergency medical transport payments, as referenced in paragraph three herein. The amounts to be voluntarily transferred to DHCS will be based on an estimate, the Public Entity acknowledges that a reconciliation of the voluntary NFS contributions to the actual NFS expenditures will occur. To the degree necessary to fund the NFS for the PP-GEMT Program, amounts due to or owed by the Public Entity as a result of the reconciliation may be offset against, or added to, future transfers as applicable and as determined by DHCS. DHCS may accept a voluntary contribution to the extent it is able to obtain FFP for PP-GEMT payments as permitted by federal law. 8. The Public Entity acknowledges that all records of funds transferred are subject to review and audit upon DHCS' request. The Public Entity will maintain documentation supporting the allowable funding source of the IGTs. 9. Upon notice from the federal government of a disallowance or deferral related to this IGT, the Public Entity responsible for this IGT shall be the entity responsible for the federal portion of that expenditure. hereby declare under penalty of perjury under the law of the United States that the foregoing is true and correct to the best of my knowledge. I further understand that the known filing of a false or fraudulent claim, or making false statements in support of a claim, may violate the Federal False Claims Act or other applicable statute and federal law and may be punishable thereunder. I DEPARTMENT OF HEALTH CARE SERVICES PUBLIC PROVIDER INTERGOVERNMENTAL TRANSFER PROGRAM FOR GROUND EMERGENCY MEDICAL TRANSPORTATION SERVICES CERTIFICATION FORM FOR STATE CALENDAR YEAR 2025 Executed on this day of , 2025 at Signature of Authorized Person: Name of Authorized Person: Grace K. Leung Title of Authorized Person: City Manager Name of Public Entity: City of Newport Beach NPI of Public Entity: 1679579296 Amount of IGT: $82,686.25 California. APPROVED AS TO FORM: CITY ATTORNEY'S OFFICE Date: _AV 18-7 PRoHICS CALIFORNIA DEPARTMENT OF HEALTH CARE SERVICES Michelle Baass I Director PUBLIC PROVIDER GROUND EMERGENCY MEDICAL TRANSPORTATION (PP-GEMT) PROGRAM MANAGED CARE AND FEE FOR SERVICE - INVOICE Entity information: 1/17/2oz5 Entity Name: City Of Newport Beach Payment Details: Year: 2025 Collection #: i NPI: 1679579296 Total Amount Due: $82,686.25 Program/Payee Information: Banking Information: Vendor Name: Bank Name: California Department of Health Care Services US Bank Please await Wire Request Memo for payment instructions PP-GEMT Program Email: Payment Methods Accepted: AB1705@dhcs.ca.gov ACH or Wire Transfer Payment Instructions: Attention: Please review, sign, and submit the Intergovernmental Transfer (IGT) Certification form by January 3, 2025, to AB1705@dhcs.ca.gov. IGT Certification forms are required to be submitted Prior to each collection due date. Once the IGT Certification form is received, DHCS will send a Wire Request Memo providing payment details and instructions. Please do not send your IGT payment until you have received the Wire Request Memo as payment details are subject to change. DeliveryIGT Non -Federal Share (NFS) Breakdown By DHCS Managed -Care (MC) MC NFS #1 $71,549.02 MC Admin Fee #1 $0.00 Fee For Service (FFS) FFS NFS #1 $11,137.23 FFS Admin Fee #1 $0.00 Total's IGT Transfer Amount: $82,686.25 *Any differences are due to rounding. CY 2025 Invoice #1 Invoice Packets Sent 22/3/2024 IGT Certifications Due 1/312025 Pa ment Due 1/17/2025 CY 2075 Invoice #2 Invoice Packets Sent 3/4/2025 iGT Certifications Due 4/4/2025 Payment Due 4/18/Zf125 CY 2023 FFS Recon Date of Service Jan - Dec 2023 CY 2024 MC Recon #1 Date of Service Jan - Jun 702 CY 2025 Invoice 03 Invoice Packets Sent 6/3/2025 IGT Certifications Due 7141702 Pa ment Due 7/19/2025 CY MS Invoice 94 Invoice Packets Sent 9/2/2025 IGT Certifications Due 10/3/2025 Payment Due 10/17/202S CY 2024 MC Recon #2 Date of Service Jul - Dec 2.02 18-8 ATTACHMENT B �iHCS NOTICE OF GENERAL PUBLIC INTEREST CoEALTNICARESERVICEF RELEASE DATE: DECEMBER 10, 2024 HEALTH CARE SERVICES PROPOSED STATE PLAN AMENDMENT TO EXTEND THE PUBLIC PROVIDER GROUND EMERGENCY MEDICAL TRANSPORT INTERGOVERNMENTAL TRANSFER PROGRAM This notice is to provide information of public interest about a proposed State Plan Amendment (SPA) by the Department of Health Care Services (DHCS). SPA 25-0002 proposes to continue the Public Provider Ground Emergency Medical Transport Intergovernmental Transfer (PP-GEMT IGT) Program in calendar year (CY) 2025 to continue providing an add -on increase for eligible Ground Emergency Medical Transport (GEMT) services for dates of service January 1, 2025 to December 31, 2025. California Welfare and Institutions Code (WIC) section 14105.945, enacted by Assembly Bill (AB) 1705 (Chapter 544, Statutes of 2019), authorizes DHCS to implement the PP- GEMT IGT Program for public providers of GEMT services. Providers are eligible to participate in the program if they meet all of the following criteria: (1) provide GEMT services to Medi-Cal beneficiaries, (2) are enrolled as a Medi-Cal provider for the period being claimed, and (3) are owned or operated by the state, a city, county, city and county, fire protection, special, community services, or health care district, or a federally recognized Indian tribe. The add -on increase will be in addition to the fee -for -service fee schedule rates for GEMT services billed using the procedure codes listed below. Pursuant to SPA 22-0015, the Department was authorized to provide an add -on through the PP-GEMT IGT Program for dates of service January 1, 2023 through December 31, 2023. SPA 22-0015 established an initial add -on rate of $946.92 for each qualifying transport for CY 2023 pursuant to the requirements of WIC section 14105.945(d)(1) and (2). Pursuant to WIC section 14105.945(d)(3), for subsequent rating periods, DHCS is authorized to periodically adjust the initial add -on rate to account for inflation, trend adjustments, or other material changes. In SPA 24-0002, which is pending Centers for Medicare and Medicaid Services (CMS) approval, DHCS proposes to adjust the initial add -on rate for CY 2024 pursuant to Section 14105.945(d)(3). Through this SPA, DHCS proposes to adjust the initial PP-GEMT IGT Program add -on for CY 2025 pursuant to Department of Health Care Services Fee For Service Rates Development Division State of California Gavin Newsom, Governor 18-9 Section 14105.945(d)(3). Effective January 1, 2025, through December 31, 2025, eligible public providers may receive an add -on increase for the following procedure codes: Procedure Code Description Estimated Medi- Cal PP - GEMT IGT Add -on Amount A0429 Basic Life Support $1,478.68 A0427 Advanced Life Support, Level 1 $1,478.68 A0433 Advanced Life Support, Level 2 $1,478.68 A0434 Specialty Care Transport $1,478.68 A0225 Neonatal Emergency Transport $1,478.68 Public providers are not eligible to participate in the GEMT Quality Assurance Fee (QAF) program for periods when the PP-GEMT IGT Program is in effect. DHCS estimates that the annual aggregate Medi-Cal expenditures for GEMT services will increase by $24.5 million in total funds for Calendar Year 2025. The effective date of the proposed SPA is January 1, 2025. All proposed SPAS are subject to approval by the CMS. Public Review and Comments Upon submission to CMS, a copy of proposed SPA #25-0002 will be published at the following internet address: https://dhcscagovauthoring/formsandpubs/laws/Pages/Pending-2025.aspx If you would like to view the SPA in person once it becomes available, please visit your local county welfare department. You may also request a copy of proposed SPA #25- 0002 using the mailing or email address listed below. Written comments may be sent to the following address: Department of Health Care Services Fee -For -Service Rate Development Division Attn: Michelle Tamai P.O. Box 997413, MS 46000 Sacramento, California 95899-7417 DHCS - NOTICE OF GENERAL PUBLIC INTEREST F 18-10 Comments may also be emailed to Publiclnput@dhcs.ca.gov. Please indicate SPA #25- 0002 in the subject line or message. A copy of submitted public comments to SPA #25-0002 may be requested in writing to the mailing or email address identified above. DHCS - NOTICE OF GENERAL PUBLIC INTEREST 3 18-11