Can other unaffiliated air medical providers honor Air Evac Lifeteam memberships?

For other unaffiliated air medical providers, we do not believe so. Federal law prohibits the routine waiver of co-pays for services covered by Medicare or Medicaid. However, through an ambulance membership program, membership fees are collected in lieu of the collection of co-pays (“co-pays” is used to refer to all types of patient cost-sharing amounts, including co-payments and deductibles).

OIG guidance provides that where membership fees collected from members (or members who are Medicare beneficiaries) “reasonably approximate” the amounts that these individuals would expect to spend for cost-sharing amounts over the period covered by the membership agreement, there is, essentially, no impermissible waiver of co-pays. Therefore, where a specific air ambulance supplier (such as Air Evac Lifeteam) operates a membership program and does not bill its members for co-pays associated with its air transport services, this would not be considered to be a prohibited waiver of the co-pays ( ... more.

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