Georgia Emergency Medical Services Association (GEMSA)
Position statement on the Upper Payment Limit (UPL) Program

June 18, 2019

The Georgia Emergency Medical Services Association is the statewide association representing Georgia’s EMS community. In regards to the proposed Ambulance Upper Payment Limit (UPL) Supplemental Payment Program, we are unable to support the program as its current version primarily benefits one service and we ask the Department of Community Health to withdraw the proposal for further revision.

We are concerned on several positions in regards to what has been in place, and what is currently being considered for changes to the new UPL Program. Currently,  all licensed EMS providers pay annual license fees on vehicles that are placed into the Indigent Care Trust Fund and used as a state match to draw down federal dollars. These funds are supposed to be used to enhance Medicaid reimbursements for all types of EMS services, not just hospitals. The historic benefit to EMS from this enhancement program has been limited, the anticipated reimbursement increases have not materialized, and most importantly, as the amount of fees have increased over the last five years, that money has NOT been put toward reimbursements for EMS, but rather other priorities in Medicaid.

Until the current license fee reimbursement program is corrected and updated, and all ambulance providers serving Medicaid are aided, we are unable to support a new payment program that is targeted at just one type of ambulance service, such as the ambulance UPL proposal, where a very small group will benefit, and one agency overall receiving the vast amount of the $33,000,000 estimated to be available with the UPL Program.

Additionally, this specific program is geared toward one type of service - hospital based ambulance services. While we advocate for everyone and would have issues singling out any specific type, in this case, hospital based services do make up the smallest portion of 9-1-1 providers in our state. Thus the department’s proposal is initially excluding of the majority of EMS. While it may be true that non-hospital based providers can work with hospital authorities on agreement, logistically that was not a reality for most providers with the limited notice provided to services to apply for this program. Most never received proper notification to apply from DCH, and the Department of Public Health actually provided notice to most ambulance services, but it was less than 48 hours before the original deadline. In fact, our association had to ask for an extension of the original deadline just so a few of the hospital based and other services could apply for this initially. Thus, this process to get here today was not as encompassing and inclusive as it could have been.

It's unfortunate to be in this position, given that we have worked tirelessly for nearly two decades to help provide more funding to the EMS profession. But in its current version, GEMSA is opposed to the Ambulance UPL Supplemental Payment Program and asks the board to withdraw consideration at this time. 

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We encourage our members to oppose the UPL proposal in its current form.  Please see the public notice here for more information on how to submit written comments.

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