If you have ever had to complete a Medicare 855 Form, particularly the ambulance attachment, you know how difficult it can be to fill out the form and comply with this terribly burdensome requirement.  The form requires that you list each EMT and paramedic and provide a copy of his or her license as well as list each vehicle and provide a copy of its registration, all equipment and supplies.  You then must promptly notify the Centers for Medicare and Medicaid Services (CMS) each time you have a vehicle or crew change and provide the new information.

When the ambulance attachment to Medicare 855 Form was imposed on providers, the AAA made it a top priority to try to eliminate its more onerous requirements.  I am pleased to report that we have made huge progress on the issue.  However, we need your help to finish the job.

On January 27, 2006, CMS published a notice in the Federal Register seeking public comment on proposed revisions to the Medicare provider enrollment application (855 Form).  Among the proposed revisions is the elimination of the requirement that ambulance companies notify CMS of any changes in crewmembers.  In addition, on February 9, 2006, CMS issued a Joint Signature Memo eliminating this requirement for existing ambulance companies who have previously completed the enrollment form.  For now, new companies and companies filing new enrollment applications will still be required to provide crew member information in Attachment 1 to Form 855B.  If the proposed revisions are adopted, this requirement will be removed for new companies as well.

            This policy change represents a significant victory for the industry!

Unfortunately, the proposed revisions would retain the requirement that CMS be provided with information about each vehicle.  As companies are required to register all vehicles with existing state and local agencies, the requirement that companies also register these vehicles with CMS is duplicative and unduly burdensome on companies.

For this reason, we strongly urge all AAA members to respond favorably to the decision to remove the crewmember notification requirement, and to recommend that CMS further remove the vehicle requirements.  We are enclosing a sample response letter (however, we encourage companies to customize this letter to their own situation) for you to submit on the notice.  The Office of Management and Budget must receive all comments by February 27, 2006.  Please mail your comments to:

OMB Human Resources and Housing Branch

Attn: Carolyn Lovett, CMS Desk Officer,

New Executive Office Building

Room 10235

Washington, D.C. 20503