News & Updates

Earlier this year, the Academy of International Mobile Healthcare Integration (AIMHI) released our bi-annual 2024 Benchmark Report. While that report covered high-level metrics, respondents supplied a plethora of valuable, granular detail regarding operational and financial metrics.

We are releasing this BONUS EDITION of the Benchmark Report, detailing the Financial Metrics achieved by these High-Performance/High Value (HP/HV) EMS systems.

We encourage public policy officials and EMS system leaders to compare their performance metrics with these systems.

If you would like any assistance developing your metrics, please feel free to contact us at hello@aimhi.mobi

Key Takeaways from this Report include:

• 59.7% of emergency services provided by participating AIMHI agencies were billed at the ALS-Emergency level, and 36.1% were billed at the BLS-Emergency level.

• The average expense per transport for participating AIMHI agencies was $532.47. The average expense per capita was $72.88.

• Among participating AIMHI agencies, the Average Patient Charge (APC) was $1,343.12, with a low of $740.00 and a high of $1,969.52.

• Among participating AIMHI agencies, the average reimbursement per transport was $427.58. Average patient self-pay reimbursement was $53.47, average Medicaid reimbursement was $228.09, average Medicare reimbursement was $435.94 and average commercial insurance reimbursement was $859.43. On average, Medicare Advantage reimbursement was $50 less than Fee for Service Medicare.

• Commercially insured patients represented 16.2% of the patients served, but 32.9% of the patient services revenue received.

Click the link below to view and download the full BONUS EDITION: Financial KPIs Report:

2024 High Performance-High Value EMS Delivery KPIs - Financial.pdf

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Our desire in releasing these performance metrics is to assist local policy makers and EMS leaders evaluate their EMS system’s performance, balanced with the needs and desires of the community the system serves.

These are examples of financial KPIs for some of America’s highest performing EMS systems.

No two systems are alike, and variables such as cost of service delivery, payer mix, average patient charge and revenue cycle management procedures could impact the economic sustainability of the local EMS agency.

Earlier this year, the Academy of International Mobile Healthcare Integration (AIMHI) released our bi-annual 2024 Benchmark Report. While that report covered high-level metrics, respondents supplied a plethora of valuable, granular detail regarding operational and financial metrics.

We are releasing this BONUS EDITION of the Benchmark Report, detailing the Operational Metrics achieved by these High-Performance/High Value (HP/HV) EMS systems.

We encourage public policy officials and EMS system leaders to compare their performance metrics with these systems.

If you would like any assistance developing your metrics, please feel free to contact us at hello@aimhi.mobi

Key Takeaways from this Report include:

The per-Capita response rate for participating AIMHI member agencies was 0.18961, meaning a ‘typical’ 100,000 population community would generate 18,961 EMS responses.

To meet this response demand, participating AIMHI agencies scheduled an average of 0.37305 unit hours per Capita, meaning an average of 37,305 ambulance unit hours per 100,000 population, or the equivalent of 4.3 ambulances per 100,000 people.

Response Unit Hour Utilization (UHU-R) for AIMHI agencies participating in the survey was 0.508, essentially meaning on average, an on-duty ambulance was assigned to a response 50.8% of the time they were on-duty.

Respondents reported achieving an average of 90.1% scheduling efficiency, meaning they were able to provide 90.1% of the planned unit hours.

Click the link below to view and download the full BONUS EDITION: Operational KPIs Report:

2024 High Performance-High Value EMS Delivery KPIs - Operational - FINAL.pdf

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Our desire in releasing these performance metrics is to assist local policy makers and EMS leaders evaluate their EMS system’s performance, balanced with the needs and desires of the community the system serves.

These are examples of operational KPIs for some of America’s highest performing EMS systems.

No two systems are alike, and variables such as how long it takes to complete an EMS response due to factors such as travel distances, hospital delays and desired response times could impact the resources needed to effectively serve the community.

The results would be exceptionally valuable information for the industry!

Announcing the National EMS Documentation Survey

PWW|AG is excited to announce the National EMS Documentation Survey, which will identify attitudes, challenges, and issues inherent in documenting EMS patient interactions. EMS leaders have consistently identified high quality clinical and operational documentation as one of their organizations' most vexing and persistent challenges. The National EMS Documentation Survey may be completed by any individual with a role in EMS, including EMS practitioners, medical directors, EMS leaders, managers and executives, EMS billing and revenue cycle management professionals, and others. The Survey will measure critical issues such as: EMS provider and leadership attitudes toward patient care report (PCR) documentation; Comfort with and ease of use of EMS PCR technology; Sufficiency of time allocated to PCR documentation; Need for training and education on EMS documentation issues; The Survey takes an estimated 10-15 minutes to complete. The results will help provide insight and research into improving EMS patient care reporting documentation and will help provide the tools and support that EMS professionals need to produce high-quality documentation. To access the Survey, visit: https://www.surveymonkey.com/r/EMSDocumentationSurvey or use the QR code below.

Outstanding guidance from this recently released Consensus Statement of the National Association of EMS Physicians International Association of Fire Chiefs and the International Association of Chiefs of Police on best practices for collaboration between law enforcement and emergency medical services during acute behavioral emergencies.

Two of the principal authors of the National Consensus Statement, Drs. Kupas and Miller, will be presenting an overview of the paper at the upcoming EMS Law and Policy Symposium on Medical Civil Rights in Emergency Services.  The Symposium will be held this Thursday, November 7^th, at the Widener University Commonwealth Law School in Harrisburg, PA. 

Symposium registration is free, and the program will be available remotely via Zoom. 

In addition to a discussion of the new Consensus Statement, the Symposium will also include attorneys from the litigation team on the Elijah McClain case in Colorado, and representatives of the Harvard-affiliated Medical Civil Rights Initiative. For more information and to register, visit:

https://commonwealthlaw.widener.edu/current-students/law-school/events/detail/3516/

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Consensus Statement of the National Association of EMS Physicians International Association of Fire Chiefs and the International Association of Chiefs of Police: Best Practices for Collaboration Between Law Enforcement and Emergency Medical Services During Acute Behavioral Emergencies

https://pubmed.ncbi.nlm.nih.gov/39264840/

There must be an awareness of the potential for bias such as anchoring bias, ascertainment bias, and confirmation bias. We must make a conscious effort at an independent assessment of the individual. The goal is to optimize the individual’s safety with the minimal use of force or restraint, yet still provide for the safety of first responders and bystanders.

Medical Evaluation

The potentially competing priorities of LE and EMS also need to be recognized and addressed as part of conjoint education and training to ensure collaboration in the assessment and any required clinical treatment of these individuals.

Optimally, LE should give a short, objective summary to EMS on the circumstances of the encounter. This summary should include the reason for the encounter, pertinent observed behaviors, medical history that may have been volunteered by the individual or bystanders, descriptions of any use of force and/or the use of less lethal weapons that may have been employed, as well as any other potential sources of trauma.

Emergency medical services must have access to the patient for clinical assessment, which may require transition from LE positioning and restraints to medical positioning and restraints. Law enforcement may provide input on the threat posed by transitions so that the team can collaborate to arrive at the safest solution that allows for the provision of any needed clinical care.

Foremost is the need to identify and treat a potentially life-threatening medical condition, including, but not limited to, hypoxia, hypoglycemia, metabolic derangements, hyperthermia, cardiac conditions, and trauma. The EMS clinicians must also be cognizant of possible toxidromes as a potential cause of the patient’s behavior, which may require immediate treatment.

Restraints and Patient Positioning

A decision to utilize pharmacologic management shall be made solely by EMS based upon their independent patient assessment and in strict accordance with EMS protocols and medical director oversight.

Transport

In some cases, LE may choose to transport the individual either to a medical facility or directly to a facility for legal remand. In these situations, it is important – when indicated – that EMS be utilized as a resource in these decisions. Although EMS clinicians may be asked by LE to evaluate an individual prior to transport to a detention facility, they should not provide a medical “clearance” without a complete clinical assessment.

Some of these individuals require advanced medical assessment and interventions not available to EMS. In situations when EMS is transporting, LE and EMS should ensure there are sufficient personnel with the appropriate scope of practice to address medical contingencies and continue any required physical restraint during transport. The monitoring and care in this setting should be delineated by EMS agency protocols and policies.

An interesting and growing trend as the EMS economics crisis presses on.
 
Agencies and communities that subsidize EMS now billing neighboring communities for mutual aid, especially jurisdictions who are not providing public funding, and as such, have difficulty with EMS responses.
 
The public policy argument is that a community paying for EMS delivery should not have the resources they are funding responding outside their community to provide primary EMS response to neighboring communities whose systems are unable to response, due to lack of funding.
 
A survey on EMS Economics published by NAEMT in 2023 revealed the cost trends in mutual by some agencies.

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Rapho supervisors OK solicitor to defend against invoice from MESA
ROCHELLE A. SHENK
Oct 29, 2024
 
https://lancasteronline.com/news/regional/rapho-supervisors-ok-solicitor-to-defend-against-invoice-from-mesa/
 
When: Rapho supervisors meeting, Oct. 17.
 
What happened: Supervisors authorized the township’s solicitor, Susan Peipher of Apple, Yost & Zee, to defend against efforts by Municipal Emergency Services Authority to collect charges against the township for medical services provided to township residents.
 
Cost: The township received a $6,200 invoice from MESA for services rendered to residents in September.
 
Background: MESA was formed in an attempt to create a fiscally sustainable model for providing emergency medical services in the region Northwest EMS formerly served. Northwest EMS had been the township’s emergency medical services provider; however, supervisors voted against joining MESA. Since January, Rapho’s emergency medical services provider has been Penn State Health Life Lion.
 
Township discussion: Township Manager Randall Wenger said he had discussed MESA’s invoice with Lori Shenk, the township’s emergency management coordinator. Shenk, who is also a first responder and had served as Northwest EMS community outreach manager, said she had concerns with the township paying the invoice without discussing it with the solicitor. She said she felt it could set a precedent.
 
Quotable: In an Oct. 18 email Shenk said, “To the best of my knowledge/understanding, Rapho Township does not have a contract or agreement with MESA and I do not know municipal law or the laws pertaining to the authority, therefore I believe it’s prudent for the township to have their solicitor determine if there is an obligation to pay any invoices from MESA.”
 
MESA viewpoint: Justin Risser, MESA treasurer and Conoy Township supervisor, said in an Oct. 18 phone call that Rapho is one of four municipalities served by Penn State Health Life Lion to receive an invoice for mutual aid service for September. Risser said mutual aid represents about 10% of MESA’s calls, and residents in the municipalities that are part of MESA are paying for it. Mutual aid occurs when a municipality’s emergency service provider is unable to provide service and another provider is called.
 
More: Risser said MESA noticed an issue with mutual aid calls to cover for Life Lion since the beginning of the year, but they’ve increased over time. The residents in the four municipalities that were invoiced also will receive an invoice for the difference between what their insurance pays and the cost for the specific service, Risser said. With the four municipalities, he said MESA is trying to cover a shortfall in the payment for the cost of service.
 
Quotable: “We want to help out (by providing mutual aid), but it’s not fair to our residents (who) are paying a fee for our services,” he said. “The intent of these invoices to municipalities is to encourage them to have a conversation with their provider. Their provider (Life Lion) is not being truthful with the municipalities about their coverage rate.”

As the period for Medicare Ground Ambulance Data Collection System (GADCS) submissions starts to wind down, the Academy of International Mobile Healthcare Integration (AIMHI) is interested in doing a cost and revenue analysis, using data submitted to Medicare, in advance of Medicare finalizing their assessment. We believe this advance assessment will serve two key purposes for the industry:

• Provide valuable information to the EMS profession about costs and revenues for service delivery that can be used to advocate for reimbursement changes.

• Provide a 'gut check' on what the data shows so that when Medicare does release their analysis, the industry will have some 'ground truth' on pre-assessment of the same data submitted to Medicare.

We commit to releasing an only aggregated data, without any agency identifiers. However, for additional assurance, agencies can either 'stamp' their PDF with 'Confidential', or include 'confidential' in the file name.

The secure link to upload the PDF files is: https://pwwemslaw.sharefile.com/i/i97ecb1d33dc479d9

Thank you!
Chip Decker, President

Below are the instructions for the secure file upload. If you have any questions, or would like support setting this up, feel free to contact Matt Zavadsky at Matt.Zavadsky@pwwadvisorygroup.com, or by phone/text at 817-991-4487.
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Click on the link below: https://pwwemslaw.sharefile.com/i/i97ecb1d33dc479d9 You'll be prompted to set up a login:

Once created, you'll be prompted confirm your email and create a password - once completed, you'll be navigated to the link to upload your GADCS file.

CMS Transmittal: 12896

https://www.cms.gov/files/document/r12896cp.pdf 

Full transmittal here: 2025 CMS AFS AIF Memo.pdf

The CDC released a series of reports on 10/9/2024 highlighting EMS delivery challenges.

The reports are summarized below, and there are links to PDFs of the full reports at the end of the summary.

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Emergency Medical Services (EMS): A Look at Disparities in Funding and Outcomes

https://www.cdc.gov/ems-community-paramedicine/php/us/disparities.html

Key points

• Substantial geographic disparities in emergency medical services (EMS) exist based on urbanicity—for example, in rural areas more staff volunteer or work part time, response times are longer, paramedics typically have lower levels of certification, and EMS relies heavily on fee for service funding.
• EMS response times for patients with cardiac arrest are 10% longer in low-income neighborhoods than in high-income neighborhoods.
• Studies find substantial disparities in the provision of EMS based on race and sex.
• In a case study of eleven counties in California, local EMS agencies that served rural counties had lower per capita EMS funding and lower percentages of cases that met established quality standards.

Nationwide EMS challenges

Despite widespread popular support for additional EMS funding, limited EMS resources contribute to service-related challenges throughout the nation. Recruiting qualified emergency medical technicians (EMTs) can be difficult because of:

• Low salaries (national average: $34,320)
• High turnover
• Lack of racial equity among staff (in 2019, 86.6% of EMTs were White)
• Insufficient operations support:
• • Reports of ambulances held together with duct tape
  • Reports of bake sales to raise money for fuel
• Little recognition of EMS role in public health
• Poor opportunities for staff training

Geographic disparities in EMS

Geographic disparities in EMS based on urbanicity have been identified nationwide. Specifically, rural areas have:

• Greater reliance on volunteers and/or part-time staff
• Paramedics with basic, rather than advanced, life support certification
• EMS paramedics who are less likely to receive prearrival instructions
• Heavier reliance on fee-for-service funding
• Longer prehospital response and transport times
• EMS systems that lack consistent medical oversight, which affects outcomes
• Higher rates of patients who require EMS transport
• Substantially higher costs for pregnant women with preterm labor

Emergency Medical Services (EMS): Local Authority, Funding, Organization, and Management

https://www.cdc.gov/ems-community-paramedicine/php/us/local-authority.html

Key points

• Unlike police and fire services, emergency medical services (EMS) are rarely classified and funded as "essential services."
• EMS are primarily funded at the local level and often severely underfunded.
• Administration, management, and oversight of EMS systems vary greatly but typically involve collaboration among multiple sectors.
• Local government autonomy may play a crucial role in giving local governments the flexibility to create and fund EMS with limited local resources.

Emergency Medical Services (EMS)_ Local Authority, Funding, Organization, and Management _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Equity in U.S. Emergency Medical Services (EMS)_ A Case Study in California _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Table 2b_ State Laws for Mutual Aid Contracts, Bonds, and Fees in Effect as of January 31, 2022 _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Table 2a_ State Laws Related to Statewide Local Government Autonomy in Effect as of January 31, 2022 _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Table 1_ Summary of Laws Pertaining to Local Government Autonomy and Local EMS Funding Mechanisms, in Effect as of January 31, 2022 _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Emergency Medical Services (EMS) Home Rule State Law Fact Sheet _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Appendix_ Detailed Methodology and Data Sources _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

Emergency Medical Services (EMS)_ A Look at Disparities in Funding and Outcomes _ Emergency Medical Services (EMS) and Community Paramedicine _ CDC.pdf

EMS on Life Support_Expectations vs Reality.pdf

EMS On Life Support: The Alarming Gap Between Expectations and Reality

What should you expect when you call 911 for an ambulance? For decades, the expectation has been to see an ambulance racing down the street with lights flashing and sirens blaring as Paramedics and Emergency Medical Technicians (EMTs) rush to the scene of a medical emergency. In reality, time is a factor in a small percentage of the calls EMS respond to and a large portion of calls to 911 today aren’t for medical emergencies. The idea fast equates with quality was pushed by the Emergency Medical Services (EMS) profession as some emergencies, such as cardiac arrests and strokes, depend on rapid responses for the best outcomes. While time is a factor for these emergencies, they make up a small number of EMS responses. Still, EMS response times are what many localities look to as the key measure of the success of their EMS system with the expectation that all calls to 911 are emergencies and need a quick response. EMS today plays a larger role in healthcare and emergency preparedness, often providing services for which there is no compensation. The gap between expectations and reality has strained EMS systems nationwide, impacting response times, financial sustainability, staffing and patient care. If the gap between expectations and reality isn’t closed, the problems facing EMS and the essential service it provides to the public could hit a breaking point. In some places, it already has. 

Recently, a joint statement from national and international healthcare and civic organizations called on localities to modernize how they measure an EMS system’s success beyond response times. While speed is helpful in some cases, in most responses it can do more harm than good. A 2020 study published in the National Library of Medicine, looking at nearly 6 million calls from almost 1,200 agencies across the country, showed less than 7% of 911 calls for EMS dealt with potentially life-saving interventions even though lights and sirens were used to respond to calls 86% of the time. Another study published by the National EMS Quality Alliance found it was more dangerous to the crews, patients and the public to use lights and sirens that often. In reality, fast does not equate with quality for most 911 calls. EMS systems are being evaluated and sometimes replaced because of an outdated metric. We must ask ourselves, are we doing what’s best for patients or changing for the sake of change in hopes ambulances will arrive more quickly? We should be measuring patient outcomes, how successfully staff are providing appropriate treatment according to the latest research and guidelines and when it is truly a factor, response times.

At its inception, the expectation was EMS would be used for medical emergencies. In today’s reality, EMS is a catchall. Many EMS responses aren’t for emergencies and sometimes do not require any medical assistance at all. At times, patients could be better served with a visit to an urgent care facility, a virtual visit with a doctor, or a response from a behavioral health professional or social services. Research published earlier this year, looking at nearly 2 million EMS responses, found 27% of the responses fell into this category. As call volume for these types of calls has increased, many EMS agencies have been stretched thin. As a result, callers get angry when an ambulance doesn’t arrive in minutes.

What is most troubling, is sometimes it is the patients who are suffering a life-threatening emergency that are having to wait longer. If we aren’t amplifying and using options more appropriate for patients than a call to 911, we are putting those who need lifesaving help at risk.

In February, a bipartisan group of legislators in Minnesota declared an “EMS Emergency,” asking for a $120 million infusion to address short-term funding challenges and strain on current EMS systems, with providers saying EMS in the state was on the brink of collapse. An industry media tracker has identified thousands of media reports on the economic crisis in EMS nationwide.

The reimbursement and funding models for EMS need to be restructured so agencies have access to consistent federal, state and local funding and are paid for services beyond the transportation of patients.

Additional funding is essential but we must also reset expectations so they’re more in line with reality. Failure to change will lead to more expensive alternatives, could result in lower quality care and could drive any current and future EMS employees away from the profession. That’s where we are headed if we do not close the gap between expectations and reality. We know the problems, now is the time for all of us to have an honest conversation about the solutions.

Richard (“Chip”) H. Decker, III

President, AIMHI

About the author:

Chip Decker serves as the CEO of the Richmond Ambulance Authority (RAA) located in Richmond, VA.  His duties extend to administering the high-performance system design to deliver clinical excellence in the most economically efficient way possible.  He currently serves as the Board President for the Academy of International Mobile Healthcare Integration (AIMHI) and is an Affiliate Professor with Virginia Commonwealth University’s (VCU) Department of Health Administration, School of Allied Health.  He currently serves as a member of the Virginia Public Safety Foundation’s Board of Directors and remains an active member of the Virginia Association of Governmental EMS Administrators (VAGEMSA).

He was a member of the Virginia EMS Advisory Board, past-Chairman of the Advisory Board’s Transportation Committee and also served on the Old Dominion EMS Alliance (ODEMSA) Board of Directors and the Richmond Metro Council.    His experience in EMS spans over 40 years and includes both volunteer and career positions. 

Chip is the recipient of a number of awards in recognition of his dedication to the EMS field.  These include an ODEMSA Award for Excellence in EMS, recognition for outstanding service from the Virginia Attorney General for his work in response to the Pentagon following the 9/11 attacks, and a commendation from the Virginia Office of EMS.  He is a life member of the Tuckahoe Volunteer Rescue Squad and received Henrico County’s Division of Police Meritorious Unit Citation for his service as Senior Volunteer Medic and member of their S.W.A.T. team.

About the Academy of International Mobile Healthcare Integration

The Academy of International Mobile Healthcare Integration (AIMHI) represents high performance emergency medical and mobile healthcare providers in the U.S. and abroad. Member organizations employ business practices from both the public and private sectors.  By combining industry innovation with close government oversight, AIMHI affiliates are able to offer unsurpassed service excellence and cost efficiency. www.aimhi.mobi | hello@aimhi.mobi | @AIMHI_MIH | www.fb.me/aimhihealthcare

This is interesting news, as many EMS providers have struggled with payers complying with outcomes of arbitration or mediation when an Independent Dispute Resolution (IDR) processes used. Some of the state-level patient protection from balance billing laws also include this provision.  The report also highlights one of the many challenges with the current No Surprises Act, likely a factor in the Ground Ambulance Patient Billing Advisory Committee's (GAPBAC) recommendation that ground ambulance providers NOT be included in the act.

It's nice to see the coalescence of associations and federal agencies about the challenges with the No Surprises Act.

Click here for an overview of the GAPBAC recommendations to Congress. 

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Federal departments, provider groups oppose HCSC in unpaid surprise billing lawsuit

By Noah Tong 

Oct 8, 2024

https://www.fiercehealthcare.com/payers/vocal-opposition-hcsc-arises-unpaid-surprise-billing-lawsuit

Major medical associations and the federal government are voicing their opinions in a controversial No Surprises Act lawsuit.

The Department of Labor (DOL), Department of Justice (DOJ), American Hospital Association, American Medical Association, Federation of American Hospitals and the Texas Medical Association are all supporting air ambulance providers against Health Care Service Corporation (HCSC), under the Blue Cross Blue Shield Association umbrella.

Insurers are required under federal law to cover emergency services, even if the care is out-of-network, as is often the case in emergency situations. Health plans are often required to reimburse providers at a fair rate after going through a lengthy independent dispute resolution (IDR) process.

In the lawsuit before the Fifth Circuit of Appeals, provider Guardian Flight underwent the IDR process with HCSC for 33 air transports, but the insurer never paid up. A district court previously ruled in favor of HCSC, saying patients are not hurt by insurers’ inaction. The court said HCSC did not violate the Employee Retirement Income Security Act (ERISA) or No Surprises Act.

HCSC did not immediately respond to a request for comment. The insurer owed nearly $1 million in payments if it followed the IDR ruling.

“Truly an awful decision,” said Julie Selesnick, senior counsel at Berger Montague, in a LinkedIn post in August. “Why would an insurer ever pay an IDR award now?”

But on Oct. 4, the DOL and DOJ argued in an amicus brief that protecting a provider's ability to recoup payments is instrumental in protecting patients against surprise medical bills, as intended by Congress when it enacted the law. The agencies said because payment following the IDR process is “tantamount to mandatory plan benefits” plaintiffs should be allowed to invoke ERISA.

Last month, Rep. Greg Murphy, R-N.C., introduced the No Surprises Act Enforcement Act. The proposed bill enforces non-compliance penalties on health plans that already exist for providers.

No payments were made after the conclusion of the IDR process 52% of the time, a survey (PDF) of 48,000 physicians from the Americans for Fair Health Care found. In the other instances, 49% of payments were not made within the required 30-day window and 33% of payments were incorrect.

CMS previously said providers are winning (PDF) No Surprises Act arbitration cases against health plans at a 77% clip.

“As argued by the DOJ, the ability to enforce IDR determinations in court is but one more necessary ‘tool in the toolbox’ for clinicians to force the health plans to comply with the law,” said Ed Gaines, vice president of regulatory affairs and industry liaison for Zotec Partners, in a statement to Fierce Healthcare.

Leading provider organizations—the American Hospital Association, American Medical Association, Federation of American Hospitals and the Texas Medical Association—agreed with the government, arguing providers’ existence would be threatened.

“It gives insurers significant leverage to demand confiscatory discounts from out-of-network providers, as well as to exact across-the-board rate cuts from in-network providers, lest they be kicked out of network and not paid at all,” the organizations said in a joint amicus brief. “Both in- and out-of-network providers will thus find themselves perpetually underpaid or even uncompensated for their valuable services, and patients will lose providers and critical care as a result.”