CAL AAMS Comment on 8-2007 DMAC Balanced Billing Rule

[PRINT ON AAMS LETTERHEAD] November ___, 2007 Emilie Alvarez, Regulations Coordinator Department of Managed Health Care Office of Legal Services 980 Ninth Street, Suite 500 Sacramento, CA 95814 Re: Comments on Proposed Rule re Plan and Provider Claims Settlement; Criteria for Determining Reasonable and Customary Value of Health Care Services; Expedited Payment Pending Claims Dispute Resolution; Definition of Unfair Provider Billing Patterns; and Independent Dispute Resolution Process; Proposed Adoption of Section 1300.71.39; and Proposed Revision of Sections 1300.71 and 1300.71.38; Control No. 2007-1253 Dear Ms. Alvarez: The Association of Air Medical Services (“AAMS”) is an international association that serves and represents more than 500 providers of air and surface service medical transport systems. AAMS is a non-profit organization which encourages and supports its members in maintaining a standard of performance and practice that reflects safe operations and efficient, Formatted: Highlightethical and high quality patient care. AAMS membership includes ___ providers that perform services in the State of California, including some of the largest air medical providers in the state. AAMS appreciates the opportunity to comment on the above-referenced Proposed Rule (the “Proposed Rule”). SUMMARY We are concerned that the Proposed Rule would exacerbate the difficulties which emergency services providers currently have in securing fair ...