BILL ANALYSIS                                                                                                                                                                                                    



                                                                AB 511
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         REPLACE - 6/1/09 APPROPRIATIONS VOTE CHANGE
         
        ASSEMBLY THIRD READING
        AB 511 (De La Torre)
        As Amended May 4, 2009
        Majority vote 

         HEALTH              19-0        APPROPRIATIONS      14-3        
         
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        |Ayes:|Jones, Fletcher, Adams,   |Ayes:|De Leon, Ammiano, Charles   |
        |     |Ammiano, Block, Carter,   |     |Calderon, Davis, Fuentes,   |
        |     |Conway, De La Torre, De   |     |Hall, Miller,               |
        |     |Leon, Emmerson, Gaines,   |     |John A. Perez, Price,       |
        |     |Hall, Hayashi, Hernandez, |     |Skinner, Solorio, Audra     |
        |     |                          |     |Strickland, Torlakson,      |
        |     |Bonnie Lowenthal, Nava,   |     |Krekorian                   |
        |     |V. Manuel Perez, Salas,   |     |                            |
        |     |Audra Strickland          |     |                            |
        |     |                          |     |                            |
        |-----+--------------------------+-----+----------------------------|
        |     |                          |Nays:|Nielsen, Duvall, Harkey     |
        |     |                          |     |                            |
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         SUMMARY  :  Imposes as a condition of participation in the Medi-Cal  
        Program a 5.5% quality assurance fee (QAF) on ambulance  
        transportation services providers until the 2015-16 fiscal year  
        (FY), and requires revenue from the QAF to be used exclusively to  
        enhance federal financial participation (FFP) under Medi-Cal or to  
        support quality improvement efforts.  Implements this bill only if  
        the state receives federal approval and legislation is enacted  
        during the 2009-10 legislative session that makes an appropriation  
        to fund a Medi-Cal rate increase for ambulance transportation  
        services providers.  Specifically,  this bill  : 

        1)Imposes, as a condition of participation in the Medi-Cal Program,  
          for each ambulance transportation services provider that derives  
          revenue from the provision of ambulance transportation services, a  
          QAF each state fiscal year based on the provision of ambulance  
          transportation services. 

        2)Requires the QAF to be assessed on all Medi-Cal ambulance  
          transportation services providers, except for a Medi-Cal ambulance  
          transportation services provider that is exempt pursuant to 19)  








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          below because the Department of Health Care Services (DHCS) had to  
          alter the provider fee methodology to obtain federal approval.

        3)Requires the amount of the QAF assessed on each Medi-Cal ambulance  
          transportation services provider to be based on the revenue  
          received by the provider from the provision of ambulance  
          transportation services and to be calculated in accordance with  
          the methodology outlined in 4) directly below.

        4)Requires, for the 2009-10 through 2015-16 FYs, the QAF for each  
          ambulance transportation services provider to be calculated by  
          multiplying by 5.5% the revenue that the ambulance transportation  
          services provider derived from providing ambulance transportation  
          services, as determined under the approved methodology.  For the  
          2010-11 to 2015-16 FYs, prohibits the QAF calculated pursuant to  
          this provision and collected under this bill, taken together with  
          applicable licensing fees, from exceeding the amounts allowable  
          under federal law.

        5)Requires DHCS to deposit the QAF collected pursuant to this bill  
          in the Medi-Cal Ambulance Transportation Services Providers Fund  
          (Fund), which is created in the State Treasury, and requires the  
          Fund to also include interest and dividends earned on moneys in  
          the Fund.

        6)Requires moneys in the Fund, upon appropriation by the  
          Legislature, to be available to exclusively enhance FFP for  
          ambulance transportation services under the Medi-Cal program or to  
          provide additional reimbursement to, and to support quality  
          improvement efforts of, ambulance transportation services  
          providers, including increased reimbursement for and improvement  
          of the quality of the provision of advanced life support services.

        7)Requires this bill to be implemented only if both of the following  
          conditions are met:

           a)   The state receives federal approval of the QAF from the  
             Centers for Medicare and Medicaid Services (CMS); and, 

           b)   Legislation is enacted during the 2009-10 session that makes  
             an appropriation from the Fund and from the Federal Trust Fund  
             to fund a Medi-Cal rate increase for ambulance transportation  
             services providers.









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        8)Requires this bill to remain operative only as long as all of the  
          following conditions are met:

           a)   CMS continues to allow the use of the QAF provided in this  
             bill;

           b)   The Medi-Cal rate increase for ambulance transportation  
             providers remains in effect; and,

           c)   The full amount of the QAF assessed and collected pursuant  
             to this bill remains available exclusively to enhance FFP for  
             ambulance transportation service providers in Medi-Cal.

        9)Permits DHCS to retroactively increase and make payments of rates  
          to Medi-Cal ambulance transportation services providers.

        10)   Requires providers that have been assessed a fee by DHCS to  
          pay the fee assessed within 60 days of the date rates are  
          increased in accordance with this bill and paid to those  
          providers.

        11)   Requires DHCS to accept a provider's payment of the fee even  
          if the payment is submitted in a subsequent rate year than the  
          rate year in which the fee was assessed.

        12)   Requires the QAF to be paid by providers to DHCS on a  
          quarterly basis on or before the last fiscal day of the fiscal  
          quarter following the fiscal quarter for which the QAF was  
          imposed. 

        13)   Requires each provider paying a QAF to submit with the fee  
          paid, in a form prescribed by DHCS, data on the gross receipts  
          from the provision of ambulance transportation services provided  
          during the fiscal quarter for which the fee is being paid in order  
          for DHCS to verify the accuracy of the QAF paid.

        14)   Permits DHCS, when a provider fails to pay all or part of the  
          QAF within 60 days of the date that payment is due, to deduct the  
          unpaid fee and interest owed from any Medi-Cal reimbursement  
          payments owed to the provider until the full amount of the fee and  
          interest are recovered. 

        15)   Requires any deduction made pursuant to 14) above to be made  
          only after the DHCS gives the provider written notification, and  








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          permits any deduction made to be deducted over a period of time  
          that takes into account the financial condition of the provider.  

        16)   Permits DHCS, if all or any part of the QAF remains unpaid, to  
          assess a penalty on the provider equal to 50% of the unpaid fee  
          amount.

        17)   Requires the director of DHCS, or his or her designee, to  
          administer this bill, permits the director to adopt regulations as  
          are necessary to implement this bill, including emergency  
          regulations, through the rulemaking provisions of the  
          Administrative Procedure Act.  States legislative intent that the  
          regulations adopted pursuant to this bill be adopted on or before  
          July 31, 2012.

        18)   Permits the director of DHCS, as an alternative to adopting  
          regulations to implement this bill, in whole or in part, by means  
          of a provider bulletin, or other similar instructions, without  
          taking regulatory action, provided that no bulletin or other  
          similar instructions remain in effect after July 31, 2012.

        19)   Requires DHCS to request approval from the CMS for the  
          implementation of this bill, and permits the director of DHCS to  
          alter the methodology specified in this bill, to the extent  
          necessary to meet the requirements of federal law or regulations  
          or to obtain federal approval.  Permits the director to also add  
          categories of exempt ambulance transportation services providers  
          or apply a non-uniform fee to ambulance transportation services  
          providers that are subject to the fee in order to meet the  
          requirements of federal law or regulations.   Permits the director  
          to exempt categories of ambulance transportation services  
          providers from the fee, if necessary to obtain federal approval.

        20)   Requires DHCS to make retrospective adjustments, as necessary,  
          to the amounts calculated pursuant to this bill in order to ensure  
          that the QAF for any provider in a particular state fiscal year  
          does not exceed 5.5% of the revenue derived by a provider subject  
          to the fee from the provision of ambulance transportation  
          services.

        21)   Requires this bill to become inoperative in the event of a  
          final judicial determination made by any state or federal court  
          that is not appealed, or by a court of appellate jurisdiction that  
          is not further appealed, in any action by any party, or a final  








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          determination by CMS that FFP is not available with respect to any  
          payment made under the methodology implemented pursuant to this  
          bill because the methodology is invalid, unlawful, or contrary to  
          any provision of federal law or regulations, or of state law.

        22)   Requires this bill to be repealed on the date that it becomes  
          inoperative.

         FISCAL EFFECT  :  According to the Assembly Appropriations Committee:

        1)No General Fund (GF) will be used to support annual increased  
          Medi-Cal payments to ambulance providers of $100 million (50%  
          provider QAF/50% federal) to $110 million (50% provider QAF/50%  
          federal).  These figures are based on preliminary estimates of  
          5.5% of statewide aggregate ambulance revenues and are supported  
          by research in this area regarding average reimbursement by payer  
          type, distribution of patient transport by payer type and  
          frequency, and related current law reimbursements.
        2)The creation of a new funding mechanism to draw down millions in  
          federal financial participation creates GF pressure when the QAF  
          sunsets in 2016.  GF pressure is created to continue Medi-Cal  
          increases paid to ambulance providers. 

        3)Staffing costs to DHCS of $200,000 (50% GF) to implement the  
          requirements of this bill   including attaining federal approval  
          and establishing claims.

         COMMENTS  :  This bill is sponsored by American Medical Response  
        (AMR), which states this bill is the legislative vehicle for  
        statutory changes needed to craft an ambulance QAF.  AMR argues this  
        bill represents a unique opportunity to expand health care access  
        and raise the level of health care outcomes by providing a pathway  
        in state law to draw down additional federal Medicaid funding for  
        ambulance transport services.  AMR argues inadequate Medi-Cal  
        reimbursement for ambulance transport has put an enormous strain on  
        the state's health care structure and in particular, the state's  
        emergency medical services (EMS) system.  Unlike other Medi-Cal  
        providers, ambulance providers cannot limit their Medi-Cal patients  
        in order to find a survivable payor mix.  AMR states ambulance  
        providers have been recently saddled with debilitating Medi-Cal cuts  
        including last year's 10% Medi-Cal provider rate reduction, while  
        having to endure additional increases in vehicle license fees and  
        fuel costs which are significant for large emergency vehicles.  AMR  
        states that ambulance transport has the worst cost-of-service to  








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        reimbursement ratio of all health care providers in the Medi-Cal  
        system.

        AMR states there are federal dollars that can be drawn back down to  
        the state through a QAF that will permit ambulance providers to  
        establish a means to increase patient outcomes and reverse, or at  
        least slow, the rate of degradation of reimbursement rates to  
        ambulance transport.  The QAF in this bill would be assessed on  
        ambulance providers who chose to participate in the Medi-Cal Program  
        and the resulting revenue would be matched by federal funds and then  
        returned to ambulance providers in the form of an increase in the  
        Medi-Cal rate.  No additional funding through the state's GF is  
        required to affect this program and the federal dollars which will  
        flow back to the state will be used by ambulance providers to  
        maintain the high level of care that is expected of the state's EMS  
        and 9-1-1 programs.  AMR states it is committed to working  
        diligently with this partnership between the state and federal  
        authorities in crafting this important program to ensure the state  
        has a safety-net EMS system its residents can rely upon.  

        Federal law authorizes states to levy fees on health care providers  
        if the fees meet federal requirements.  Many states (including  
        California) fund a portion of their share of Medicaid Program costs  
        through a fee on health care providers.  Under these funding  
        methods, states collect funds (through fees, taxes, or other means)  
        from providers, which can then be matched with federal funds to  
        increase Medicaid reimbursement to providers.  To prevent states  
        from only levying an assessment on certain providers, federal law  
        requires provider fees to be "broad based" and uniformly imposed  
        throughout a jurisdiction, and states are prohibited from having a  
        provision that would ensure providers are "held harmless" from the  
        impact of the fee.  Forty-five states have Medicaid provider fees.   
        The health reform proposal from last session by Governor  
        Schwarzenegger and then-Assembly Speaker Fabian Nunez would have  
        levied a provider fee on hospitals through a separate ballot  
        initiative to be submitted to the voters.  That proposal would have  
        increased Medi-Cal reimbursements to hospitals as a way of reducing  
        the "hidden tax" where below-market Medi-Cal reimbursement rates  
        shift costs onto insured individuals, families, and employers.   
        California currently has provider fees on intermediate care  
        facilities for the developmentally disabled, Medi-Cal managed care  
        plans, and skilled nursing facilities.
         
        Analysis Prepared by  :    Scott Bain / HEALTH / (916) 319-2097FN:  








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