Analysis: CMS announces ET3 FAQs and request for applications

On May 22, CMMI released a request for applications document and posted frequently asked questions (FAQs) for the Emergency Triage, Treat and Transport model, which it announced in February. The pilot is a voluntary, five-year payment model that will provide greater flexibility to ambulance care teams to address emergency health care needs of Medicare beneficiaries following a 911 call. Under the ET3 model, the Centers for Medicare & Medicaid Services (CMS) will pay participating ambulance suppliers and providers to:

• Transport an individual to a hospital emergency department (ED) or other destination covered under the regulations.
• Transport to an alternative destination, such as a primary care doctor’s office or an urgent care clinic. 
• Provide treatment in place with a qualified healthcare practitioner, either on the scene or connected using telehealth. The model will allow beneficiaries to access the most appropriate emergency services at the right time and place. The model will also encourage local governments, their designees or other entities that operate or have authority over one or more 911 dispatches to promote successful model implementation by establishing a medical triage line for low-acuity 911 calls.

Takeaway

Unless health systems own an ambulance service, they won’t be able to participate. However, this is something worth watching due to the potential impact on Medicare ED visits and related inpatient admissions.

In 2016, Medicare FFS beneficiaries accounted for 28 million visits to hospital emergency departments (EDs). Among these ED visits, 19 million were outpatient ED visits, which did not result in an inpatient admission, and approximately 10 million were inpatient ED visits, which resulted in an inpatient admission.

In the same year, Medicare spent an estimated $6.2B on the technical component (hospital payment) for the ED visits that didn’t result in an inpatient visit, according to HFMA analysis of data from the 2018 MedPAC Report to Congress, excluding ancillary services.

Given that CMS is still going to pay for care in another setting, a full-blown implementation of this model would reduce spending by approximately $597M (10%), which would represent a significant number of ED visits. Although it’s difficult to determine the impact this would have on inpatient admissions, there would likely be a small reduction in those as well.