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WYOMING - In a letter to the federal Centers for Medicare and Medicaid Services, the CEOs of Wyoming’s two largest hospitals and the head of Children’s Hospital Colorado urged the government to reject an effort by the state Department of Health that seeks to lower the cost of air ambulance trips, lodging a complaint that a state health official said was premature.

“We appreciate the work the State of Wyoming and its staff did in developing the waiver process, but we fear that the proposed waiver could limit access to that care and threaten the health of Wyoming children,” the CEOs wrote. “Therefore, we urge you to reject the proposed waiver until the needs of pediatric patients are addressed.”

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The letter was signed jointly by Michele Chulick, the CEO of Wyoming Medical Center; Jena Hausmann, the CEO of Children’s; and Timothy Thornell, the CEO of Cheyenne Regional Medical Center. It was submitted Dec. 13, the last day for public comment on the plan. The hospitals wrote that they were concerned because the effort — which, if approved by the feds, would treat air ambulances as a public utility — didn’t include sufficient safeguards to ensure “child-specific expertise.”

“Unfortunately, we are concerned that this waiver would limit access to care for those pediatric patients,” the CEOs wrote in a letter that focuses on Children’s role in Wyoming. “As written, the waiver lacks safeguards or attention to child health needs and fails to ensure that the winner of the air ambulance contract would either possess or subcontract to acquire the necessary child-specific expertise.”

Further on in the letter, the CEOs add that they “fear that the proposed waiver could limit access to (pediatric) care and threaten the health of Wyoming children.”  

Wyoming’s two largest hospitals both have partnership agreements with Children’s, which operates the “only freestanding, Level One Pediatric Trauma Center in a seven-stage region,” according to the letter. As such, a significant amount of the Mountain West’s seriously sick or injured children land on Children’s helipad. 

 The plan that the hospitals oppose was crafted by the Wyoming Health Department. It would essentially treat air ambulance traffic in Wyoming as a public utility, while expanding Medicaid in a limited capacity to cover all Wyomingites’ air ambulance flights. The state would select a primary air ambulance provider through a competitive bidding process. The goal is to rein in costs of air ambulance flights, which have been rising nationally.

Franz Fuchs, a health policy analyst for the state and the architect of the waiver, said that he thought the hospitals’ concern was “premature.” The waiver, he went on, is intended as a framework for how the air ambulance system will be created in Wyoming. It’s not intended to describe what the transports would offer and who would hold the contract.

“They’re concerned about the state’s setting requirements, and there’s nothing preventing the state from having even more air ambulances,” Fuchs said. “I’m not sure it’s going to happen, per se, but the waiver enables the state to make (those decisions). ... It’s just a framework. It gives the state the power to define what (the air ambulance system) is.”

In other words, the waiver isn’t intended to address specific requirements of care. It doesn’t have such requirements or safeguards for any area, pediatric or otherwise, Fuchs continued.

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In response to a Star-Tribune request for comment that noted Fuchs’ saying the concern was premature, Children’s director of transport Joe Darmofal said that the hospital remains “uncomfortable with the lack of protections for kids’ access to care and the potential for unintended consequences.” 

 Dr. Jeffrey Chapman, the chief medical officer for Cheyenne Regional, said in a statement that the letter wasn’t intended “to express opposition” to the air ambulance proposal. He said the hospitals want to ensure patients have rapid access to high levels of care.

“To that end, we encourage the State to direct the winner of the air ambulance contract to subcontract with a partner that can comprehensively serve the neonatal and pediatric air ambulance transfer needs of Wyoming patients,” Chapman wrote.

Chapman’s comments that the letter wasn’t intended to oppose the waiver stand in contrast to the letter itself, which twice urges CMS to reject the plan. In response to a question from the Star-Tribune noting the discrepancy, Chapman wrote that “while we applaud and support the Department of Health’s efforts to address concerns around air ambulance service and support the intent of the waiver, we also share in our colleagues’ concerns about providing adequate accommodations for specialized transport such as that for children.”

Dr. Jeffrey Chapman, the chief medical officer for Cheyenne Regional, said in a statement that the letter wasn’t intended “to express opposition” to the air ambulance proposal. He said the hospitals want to ensure patients have rapid access to high levels of care.

“To that end, we encourage the State to direct the winner of the air ambulance contract to subcontract with a partner that can comprehensively serve the neonatal and pediatric air ambulance transfer needs of Wyoming patients,” Chapman wrote.

Chapman’s comments that the letter wasn’t intended to oppose the waiver stand in contrast to the letter itself, which twice urges CMS to reject the plan. In response to a question from the Star-Tribune noting the discrepancy, Chapman wrote that “while we applaud and support the Department of Health’s efforts to address concerns around air ambulance service and support the intent of the waiver, we also share in our colleagues’ concerns about providing adequate accommodations for specialized transport such as that for children.”

“I think that if the concerns raised weren’t simply about preserving revenue and referral patterns, they could have been raised and discussed as the proposal was being developed,” said Ladd, who used to oversee the Wyoming Business Coalition on Health. “There was certainly plenty of opportunity for input.”

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The hospitals aren’t alone in their opposition to the waiver. Two air ambulance companies also submitted letters to the federal government urging rejecting of the plan. One of those companies — Global Medical Response — wrote that it believed the waiver would “clearly violate a number of Federal laws, limit access to necessary and critical air medical transport services for rural and vulnerable population (sic), and fail to address the primary issues regarding the delivery of air ambulance services.”

The air ambulance companies have been vocal in their criticism of the plan since its inception earlier this year. Richard Mincer, a Cheyenne attorney who represents GMR, previously argued that there’s no real crisis of high costs affecting Wyoming residents.

Indeed, the state Health Department wrote in its presentation of the plan that 90 percent of Wyomingites who take air ambulance rides pay nothing — the cost is covered by Medicare, Medicaid or insurers. For the 10 percent who do pay, the average out-of-pocket amount is $2,250.

Still, costs born fully or in part by private insurers can still trickle down and cause premiums to rise. In 2016, the average cost of a transport nationally was $40,000. Wyoming Medicaid spends between $2 million and $3 million each year on air transports for between 400 and 500 people. The state Department of Workforce Services contributes another $2 million annually, for a maximum of 100 flights.

Diane Gore, the president and CEO of Blue Cross Blue Shield Wyoming, wrote in a letter to CMS that “the cost of health care in Wyoming is one of the most expensive in the nation and the charges of air ambulance services are part of the problem.”

“We support the creative approach provided by the State of Wyoming air ambulance 1115 waiver application and encourage CMS’ favorable consideration of the application,” Gore wrote. “Anything that can be done to ensure air ambulance access and reduce the costs of those services is of great benefit.”

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