The CARE Act of 2025 directs the Center for Medicare and Medicaid Innovation (CMMI) to implement a Comprehensive Alternative Response for Emergencies (CARE) Model within two years and run it for five years. The model authorizes Medicare Part B payments to ground ambulance providers (or entities under arrangement) for treatment services provided in response to an emergency call when there is no corresponding payable transport under section 1834(l).
It also clarifies telehealth billing mechanics for those encounters.
This is a technical but consequential shift: it creates a pathway for ambulance providers to be paid for on‑scene or telehealth‑assisted treatment without transporting a beneficiary to an emergency department, and it ties payment rates to what a transport would have generated. The model could change ambulance operational decisions, EMS protocols, billing practices, and beneficiary cost exposure — and it requires careful operational and compliance planning by providers, payers, and state regulators.
At a Glance
What It Does
Requires CMMI to add a CARE Model to section 1115A within two years that pays Medicare Part B for treatment services furnished by ground ambulance providers when an ambulance is dispatched but no Medicare‑payable transport occurs. The Secretary must set rates that generally align with transport payments and treat the patient’s location as an originating site for certain telehealth fees.
Who It Affects
Ground ambulance suppliers and entities contracting with them, Medicare beneficiaries who call 911, CMS and Medicare Administrative Contractors, state and local EMS licensing and medical‑oversight systems, and telehealth vendors that provide audiovisual medical direction.
Why It Matters
It alters long‑standing payment incentives that tied reimbursement to transport, opening reimbursement for community‑based emergency care and telehealth in the field. That can reduce unnecessary ED visits but also creates new billing pathways, regulatory interplay with state scopes of practice, and potential beneficiary cost‑sharing implications.
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What This Bill Actually Does
The bill amends section 1115A of the Social Security Act to force CMMI to test a new CARE Model that makes Medicare Part B payments for certain emergency responses that do not result in a Medicare‑payable ambulance transport. In plain terms, if an ambulance is dispatched in response to an emergency call and the on‑scene team provides treatment (including under online medical direction using audiovisual telehealth) but does not transport the patient in a way that triggers the standard ambulance transport payment, the CARE Model permits payment for that on‑scene care.
Payment under the Model is not left open‑ended: the Secretary must set rates that generally align with what would have been paid if a transport that generated payment under section 1834(l) had occurred. For telehealth furnished alongside those services, the statute instructs that the patient’s location be treated as an originating site under the specified telehealth provision, which affects how originating site fees are applied.
The Model must comply with state and local licensure and protocol requirements, explicitly allowing online medical direction through audiovisual technology.The statutory test runs for five years once implemented. Separately, the Comptroller General must provide a report within four years of implementation assessing access, patient outcomes, resource utilization, regional variation, and best practices — a built‑in evaluative mechanism intended to inform whether, and how, to continue or scale the approach.
Drafting choices in the bill also carve this Model out from one existing subsection’s standard application, creating distinct administrative treatment that providers and payers should review against current 1115A authorities.
The Five Things You Need to Know
CMMI must include the CARE Model in section 1115A no later than two years after the bill’s enactment.
The Model authorizes Medicare Part B payment for treatment services provided by ground ambulance suppliers when an ambulance is dispatched but there is no corresponding Medicare‑payable transport under section 1834(l).
The Secretary must set payment rates that generally align with what Medicare would have paid for a transport under section 1834(l) rather than creating a separate, lower non‑transport fee schedule.
If telehealth under section 1834(m) is used alongside CARE services, the patient’s location is treated as an originating site for purposes of applying the originating‑site fee rules.
The Model lasts five years, and the Government Accountability Office (Comptroller General) must issue a report four years after implementation evaluating access, outcomes, utilization, regional differences, implementation challenges, and recommendations.
Section-by-Section Breakdown
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Short title
Designates the Act as the 'Comprehensive Alternative Response for Emergencies Act of 2025' or 'CARE Act of 2025.' This is a formal naming provision with no programmatic effect, but it signals Congressional intent to frame the initiative around alternative responses to emergency calls.
Insertion into CMMI authority (1115A(b))
Amends the CMMI demonstration authority to require inclusion of the CARE Model in the set of tests CMMI must consider. The amendment also inserts a drafting exception so that one existing paragraph in 1115A applies 'except in the case of the model described in subsection (h),' which alters how that particular administrative rule interacts with the CARE Model. Parties should map this change against current 1115A administrative procedures to see which standard limitations or requirements are displaced for CARE.
Scope: which services and providers are covered
Defines the model’s scope: it covers treatment services billed under Medicare Part B by ground ambulance providers (or entities under arrangement) when there is an ambulance dispatch in response to an emergency medical call but no corresponding payable transport. The provision requires that services comply with state and local licensure and protocols and explicitly allows online medical direction via audiovisual telehealth, tying federal payment permissively to varying state scopes of practice.
Payment alignment with transport rates
Directs the Secretary to set payment rates for CARE services 'in a manner that generally aligns' payments with those that would have been made for a payable ambulance transport under section 1834(l). That phrasing gives CMS discretion over rate design but establishes an alignment principle rather than a fixed formula, meaning CMS will need to create methodology and documentation for how parity is achieved.
Telehealth originating site treatment
Specifies that when a telehealth service under section 1834(m) accompanies CARE services, the site where the patient is located counts as an originating site described in a particular clause of section 1834(m). Practically, this affects how originating‑site fees and applicability of certain telehealth payment rules are handled for field‑based telemedicine used during emergency responses.
GAO evaluation and reporting requirement
Requires the Comptroller General to report to House and Senate finance committees within four years of CARE implementation. The report must analyze access to emergency services, compare outcomes and resource use against traditional transport, assess regional and demographic impacts, identify implementation best practices and challenges, and provide recommendations — providing a legislatively mandated independent assessment mid‑way through the five‑year Model.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Medicare beneficiaries who receive on‑scene treatment: people with low‑acuity emergencies may avoid ED transports and waits, receiving definitive care at the scene or via telehealth.
- Ground ambulance providers and EMS agencies: creates a billing pathway for non‑transport care, preserving revenue for on‑scene treatment and supporting alternative service models like community paramedicine.
- Telehealth vendors and remote clinicians: opens demand for audiovisual medical direction and field telemedicine integrations that are explicitly recognized for originating‑site payment treatment.
Who Bears the Cost
- Ambulance suppliers and EMS agencies must invest in new billing systems, documentation, training, and clinical protocols to substantiate non‑transport claims and meet state licensure and medical‑oversight requirements.
- State and local EMS authorities will face costs and workload to update protocols, scopes of practice, and quality oversight to align with federal payment for on‑scene care.
- Medicare and CMS will incur administrative and oversight expenses: setting new payment methodologies, auditing non‑transport claims, and coordinating with Medicare contractors and state regulators to ensure compliance.
- Medicare beneficiaries may face new or increased out‑of‑pocket costs depending on how Part B cost‑sharing applies to CARE services, creating potential financial exposure that currently may not exist for some non‑transport interactions.
Key Issues
The Core Tension
The central dilemma is balancing improved access and efficiency against the risk of perverse financial incentives: paying ambulances for non‑transport care can reduce unnecessary ED visits and expand community response, but it also creates a new billable event that could be overused or structured to capture higher reimbursements; reconciling consistent federal payment rules with widely varying state EMS authorities and clinical oversight is the trade‑off policymakers must resolve.
The bill threads a narrow policy needle: it seeks to pay for clinically appropriate, non‑transport emergency care while tying payments to the familiar ambulance transport rate to avoid creating a second low reimbursement track. That drafting choice creates practical ambiguity. 'Generally aligns' gives CMS latitude, but it also leaves providers uncertain about whether non‑transport encounters will be paid at parity, a percentage, or under a new blended methodology — and that uncertainty complicates provider investment and contract negotiations with payers and suppliers.
Implementation will collide with state variability. EMS scope‑of‑practice rules, licensure, and medical‑oversight models differ widely; the statute defers to state and local protocols, which is necessary but means access and the model’s operational shape will vary regionally.
Telehealth rules add another layer: treating the patient location as an originating site addresses a billing barrier but raises questions about who is responsible clinically and legally when care is provided jointly by field crews and remote clinicians. Finally, the bill requires a GAO report four years after implementation while the Model runs five years — the timing may limit the federal government’s ability to act on the evaluation before the Model expires, and market participants may lobby to extend or make permanent a model before full outcomes are available.
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