CMS Proposes Caps on GEMT Payments at the Medicare Ambulance Fee Schedule Amounts

The Centers for Medicare and Medicaid Services has issued a proposed rule that could have major long-term implications for Ground Emergency Medical Transportation (GEMT) reimbursement programs nationwide.

For the first time, CMS is proposing a formal provider-specific payment limit on certain targeted Medicaid supplemental payments made to transportation providers, specifically identifying GEMT providers, air ambulance providers, and NEMT providers within the rule language.

Under the proposal, targeted Medicaid supplemental payments for GEMT providers would be limited to the equivalent Medicare Ambulance Fee Schedule (AFS) payment rates for comparable services.

CMS specifically states that Medicaid supplemental payments tied to GEMT arrangements could not exceed the applicable Medicare AFS payment amounts, including the associated base rates, mileage, geographic adjustments, and rural/super-rural add-on calculations.

This proposal represents a potentially significant policy shift because many current GEMT supplemental payment methodologies nationally are based on cost reconciliation models or Average Commercial Rate (ACR)-style calculations that can exceed traditional Medicare ambulance reimbursement levels.

CMS specifically noted concerns that some targeted supplemental payment arrangements are financed through intergovernmental transfers (IGTs) and “provider-funded mechanisms” (Provider Tax) that, in CMS’ view, may reward providers based more on their ability to finance the non-federal share than on improving Medicaid access or quality outcomes.

CMS also specifically identifies GEMT supplemental payments among the targeted practitioner/provider payment arrangements it believes require additional fiscal oversight and Medicare-based payment limits moving forward.

If finalized as written, this rule could substantially alter future GEMT financing structures, supplemental payment ceilings, SPA methodologies, and the long-term sustainability of Medicaid supplemental reimbursement programs for ambulance agencies across the country.

The payment limits would be effective with the first rating period beginning on or after January 1, 2029.

PWW Advisory Group is actively reviewing the proposed rule and will continue providing updates and strategic analysis to the EMS industry as additional guidance emerges.

Click here to see a highlighted version of the proposed rule identifying the ambulance provisions.

Click here for the release from CMS.