The Protecting Air Ambulance Services for Americans Act of 2025 amends Medicare law to give the HHS Secretary explicit authority to revise the Medicare fee schedule for air ambulance services using both previously mandated data from the Consolidated Appropriations Act, 2021 and new data submitted by providers every three years. The new submissions must cover base-level fixed and operating costs, utilization by Medicare enrollees, Medicare revenue from transports, and any other information CMS determines necessary.
The bill also forces administrative milestones: HHS must finalize the rule implementing the 2021 data collection provisions within six months of enactment, and the Government Accountability Office must produce a detailed study—on costs per base and per transport, payor mix, geographic variation, and payment adequacy—within one year after data collection begins. For payers, providers, and compliance teams, the bill replaces a partly ad hoc payment framework with a recurring, data-driven process that could change Medicare reimbursements and influence private-market pricing and network viability.
At a Glance
What It Does
The bill adds a new paragraph to section 1834(l) allowing the HHS Secretary to revise the Medicare fee schedule for air ambulance services based on specified datasets and additional data CMS will collect every three years from providers. It requires transparent stakeholder consultation when CMS proposes changes, directs HHS to finalize an outstanding data-collection rule within six months, and mandates a GAO report after data collection starts.
Who It Affects
Air ambulance operators and suppliers that bill Medicare; hospital systems and rural providers that rely on air transport; Medicare beneficiaries who use emergency air transport; CMS and HHS implementation teams responsible for rulemaking and data ingestion; and analysts at GAO and congressional committees who will receive the mandated report.
Why It Matters
Medicare currently reimburses air ambulance services under a fee schedule that providers say often fails to cover costs; this bill creates an evidence loop that can justify payment changes, potentially stabilizing access in high-cost or rural markets. The combination of mandatory reporting, a required HHS rule, and a GAO study makes future payment adjustments more likely and more defensible.
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What This Bill Actually Does
The bill inserts a new, targeted authority into Medicare law: the Secretary of HHS can revise the fee schedule for air ambulance services when doing so is supported by two kinds of data. One is the dataset Congress already required in the Consolidated Appropriations Act, 2021; the other is fresh information that CMS will collect directly from air ambulance providers every three years.
The statute specifies that the new submission must include base-level fixed and operational costs tied to furnishing services to Medicare enrollees, utilization figures for those enrollees, and Medicare revenue attributable to transports. CMS can also require additional items it deems appropriate.
Practically, this means providers will need to build or extend accounting and reporting systems to separate costs and revenues attributable to Medicare transports at the base level. CMS is given discretion about how it will use those data to change payments, but the bill insists on a transparent consultation process with stakeholders when the agency moves to revise the schedule.
The consultation requirement does not prescribe a specific decision rule or formula; it requires that stakeholder input be considered and that the process be transparent.Two administrative deadlines are built in. First, HHS must finalize and publish the rule implementing the 2021 data-collection mandate within six months of the bill’s enactment—so the underlying data pipeline must be operational quickly.
Second, once data collection begins, the Comptroller General has one year to deliver a GAO report that quantifies operating costs per base and per transport, analyzes payor mix and geographic variations, evaluates Medicare payment adequacy, and issues recommendations for improving the fee schedule. That report is designed to give Congress and CMS an independent, consolidated view of the field before or as payment changes are adopted.The bill leaves important design choices to CMS: it does not mandate specific payment increases, nor does it set floors, caps, or indexing rules.
Instead, it creates a recurring, evidence-based loop—data collection every three years, periodic opportunity to revise the fee schedule, and an independent GAO assessment—that will reduce the information asymmetry between regulators and air ambulance operators and give agencies more factual grounding for payment policy.
The Five Things You Need to Know
The bill adds paragraph (18) to section 1834(l) of the Social Security Act, explicitly authorizing the Secretary to revise the Medicare fee schedule for air ambulance services using defined datasets.
CMS must require providers and suppliers to submit, once every three years, base-level fixed and operating costs, utilization by Medicare enrollees, Medicare revenue attributable to air transports, and any additional items CMS selects.
The bill ties CMS’s authority to use the data already required under section 106 of division BB of the Consolidated Appropriations Act, 2021, meaning the 2021 data mandate is a statutory building block for fee schedule changes.
HHS must finalize and publish the implementing rule for the 2021 air-ambulance data collection within six months of this law’s enactment, accelerating an outstanding rulemaking.
GAO must deliver a report within one year after data collection begins that includes average operating costs per base, average cost per transport, payor mix, adequacy of Medicare payments, geographic cost variation, and recommendations for improving the fee schedule.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Sets the Act’s name as the 'Protecting Air Ambulance Services for Americans Act of 2025.' This is a formal label only and carries no programmatic effect, but it signals the bill’s policy focus for stakeholders and committee clerks.
Secretary may revise Medicare fee schedule for air ambulance services
Grants the Secretary of HHS explicit authority to revise the fee schedule for air ambulance services 'based on' certain datasets. The statutory text does not constrain the Secretary to a particular methodology or formula; it creates statutory cover for payment adjustments that are justified by the enumerated data sources. For compliance teams, the practical implication is that CMS could propose rule changes or payment updates tied to the outputs of the new data collection.
Uses CAA 2021 data as part of the evidentiary base
Specifies that one data input is the information Congress required under section 106 of division BB of the Consolidated Appropriations Act, 2021. That linkage folds existing statutory reporting into the new decision-making framework and avoids reinventing prior congressional data requirements, but it also makes CMS’s timeline dependent on finalizing the related rule.
Triennial reporting requirement for providers
Requires CMS to collect a package of provider-reported data every three years, including fixed and operated costs per air ambulance base attributable to Medicare enrollees, utilization metrics, Medicare revenue tied to those services, and any other items CMS designates. This creates recurring compliance obligations for providers and supplies CMS with granular cost inputs that can be used to calibrate the fee schedule, subject to CMS’s interpretive choices about cost allocation and aggregation.
Transparent stakeholder consultation on payment changes
Mandates that if the Secretary decides to revise the fee schedule, CMS must consider stakeholder input through a process described as transparent and that appropriately considers the prescribed datasets. The statute does not define the consultation mechanism (notice-and-comment, public listening sessions, or negotiated rulemaking), leaving CMS room to select an administrative pathway while obligating it to show consideration of stakeholder views.
Six-month rule finalization for 2021 data collection
Requires the Secretary to finalize and publish the rule implementing the 2021 air-ambulance data collection within six months of enactment. This deadline compresses CMS’s rulemaking timeline and creates an operational imperative to have reporting specifications, confidentiality protections, and submission systems in place quickly.
GAO study on emergency air ambulance costs
Directs the Comptroller General to produce a report within one year after data collection begins covering average operating costs per base, average cost per transport, payor mix, Medicare payment adequacy, geographic variation, and recommendations for improving the fee schedule. This independent analysis is designed to supplement CMS’s internal use of the data and to inform congressional oversight and future legislative choices.
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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
- Air ambulance operators with robust cost data systems — they gain a clear route to make the case for higher Medicare payments because CMS is required to consider detailed cost and revenue submissions.
- Rural hospitals and emergency systems that rely on air transport — a data-driven payment review could lead to reimbursements that better reflect high fixed costs in low-density areas, supporting network sustainability.
- Congressional committees and policy analysts — the GAO study consolidates national cost, payor-mix, and geographic-variation data that legislators can use to craft future statutes or oversight.
Who Bears the Cost
- Air ambulance providers (especially small operators) — must build accounting and reporting processes to submit triennial datasets, incurring compliance, accounting, and possibly third-party contractor costs.
- HHS/CMS — faces a near-term administrative and IT burden to finalize the rule within six months and to receive, validate, and analyze recurring provider submissions, potentially with limited appropriations.
- Taxpayers / Medicare Trust Funds — if CMS revises the fee schedule upward to reflect reported costs, Medicare spending for air ambulance transports could increase absent offsetting cuts or savings elsewhere.
Key Issues
The Core Tension
The central dilemma is balancing accurate, cost-reflective Medicare payments that sustain air ambulance access—especially in high-cost, rural markets—against the need to control Medicare spending and avoid creating incentives that raise overall system costs; achieving both requires reliable data and careful rate design, but the bill empowers data collection without prescribing the rate rules that would reconcile these competing objectives.
The bill creates a strong information foundation for payment changes but leaves key choices to CMS. It requires triennial cost and revenue reporting and a mandated GAO study, yet it does not prescribe how CMS must translate costs into per-transport rates or how to handle geographic cost variation in the fee schedule.
That gap gives CMS needed flexibility but also raises implementation questions: which cost allocation rules will CMS require to ensure comparability across providers; how will CMS protect commercially sensitive financial data while enabling public transparency; and how will CMS treat providers that fail to submit complete data?
Another tension is administrative capacity. The six-month deadline to finalize the 2021 data-collection rule moves quickly for a complex provider reporting regime, and recurring triennial submissions will place ongoing demands on both CMS and providers—particularly smaller or nonprofit operators with limited billing or accounting staff.
Finally, the bill does not address potential spillover effects in the commercial market: better data and higher Medicare rates could influence private insurer reimbursements and negotiation dynamics, risk shifting costs across payors, and potentially accelerate market consolidation among operators who can absorb reporting burdens.
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