Amber ground ambulance dataset reflects complexity and challenges of the industry, highlights the need to improve and continue cost data collection
April 10, 2025
The Centers for Medicare & Medicaid Services (CMS) is on the cusp of possessing the data needed to make long anticipated changes to the Medicare fee-for-service (FFS) ground ambulance payment system. It has been more than two decades since CMS revised these payment rates through a negotiated rulemaking process that was exclusive of actual cost data or inflationary considerations. Since then, the cost structure of ground ambulance entities has changed. CMS is now using the Ground Ambulance Data Collection System (GADCS) to gather ambulance cost data, as required by Congress, to offer an improved understanding of the costs of delivering ground ambulance services. Given the potential of GADCS data to improve the adequacy of Medicare FFS reimbursement rates, the American Ambulance Association developed a similar data collection device, referred to as Amber, to test these data with its membership of ground ambulance entities. Amber offers a glimpse into the current challenges of the ground ambulance industry.[i]
Health Management Associates, Inc. (HMA) assessed the Amber dataset for response rates and data quality, along with responses containing calendar year 2022 financial data. Amber response rates were low, but sample volumes were on par with prior industry surveys conducted in the past by federal agencies. The Amber sample is representative of the industry’s wide variation in entity size and geographic service area. Amber data are reliable for calculating margins, but some aspects of these data also signal that ground ambulance entities, particularly smaller entities, may have had difficulty with variable definitions or the submission process. We observe that Amber would be improved by including information on uncompensated care and more details on medication supply costs.
The 2022 financial data from Amber suggest that Medicare FFS margins, at -6 percent, had declined since GAO’s 2010 assessment and that the share of costs associated with labor has increased. Amber data also suggest that the cost structure of smaller ground ambulance entities and rural and super-rural entities differs from that of larger and more urban entities. Margins for small and rural entities are lower.
Based on our assessment of the Amber dataset and its 2022 financial, we offer several recommendations to policymakers and stakeholders. These recommendations are intended to improve future cost collection efforts that may inform payment reforms to enhance the payment accuracy of the Medicare FFS payment system for ground ambulance services.
- Provide additional educational support to respondents to improve consistency of data reporting
- Streamline and modify data collection devices to adhere to industry trends and challenges
- Develop a standardized method for assigning ground ambulance entities to geographic service area for research purposes
- Collect data on ground ambulance uncompensated care and bad debt
- Collect payer level data for cases involving treatment without transport
- Collect targeted data on top 10 medications by cost to accurately reflect costs in payment rates
- CMS should consider collecting ground ambulance cost data on a semi-regular basis
- CMS should consider phasing in the use of GADCS data to ensure that the data reflect the diversity of ambulance entities and consistent reporting of key financial variables
[i] American Ambulance Association. Ambulance Cost Collection. 2023. Available at: https://ambulance.org/advocacy/cost-reporting/.