Comment on CMS-2026-1916-0001

Re: CMS-2449-P Docket ID: CMS-2026-1916 The Mendocino County Fire Chiefs Association strongly opposes the provisions in CMS Proposed Rule 2449-P that would cap Ground Emergency Medical Transportation (GEMT) supplemental payments at the Medicare Ambulance Fee Schedule rates. The Mendocino County Fire Chiefs Association represents 22 local fire agencies serving one of California's largest and most rural counties. Our membership includes agencies that provide both Basic Life Support and Advanced Life Support ambulance transport, as well as agencies that provide emergency medical first response, but do not transport patients. The majority of calls our rural agencies respond to, regardless of whether or not they are transporting patients, are medical related calls. Fire agencies are the backbone of medical, accident and rescue response in Mendocino. Every agency depends on a functioning rural ambulance system. In Mendocino County, EMS is delivered through a volunteer-based public safety system that must be staffed, equipped, and ready to respond 24 hours a day regardless of how many patients are transported. The cost of that readiness far exceeds what is reimbursed through the Medicare Ambulance Fee Schedule, which has never reflected the true cost of maintaining an emergency medical response system. For many rural fire departments, ambulance operations already operate at a loss. Fire agencies routinely subsidize EMS with local fire tax dollars because the communities they serve have payer mixes dominated by Medicare and Medi-Cal. GEMT helps offset a portion of those losses, but it still does not fully cover the actual cost of providing service. Reducing GEMT payments just further shifts costs to local taxpayers, privately insured patients, and those paying out of pocket. Rural communities, with fewer financial resources and a greater reliance on Medicare and Medi-Cal, will be impacted first and hardest. Rural America should not be expected to provide emergency response with public reimbursement that falls far below the cost of maintaining that capability. If CMS reduces one of the few remaining mechanisms that helps keep rural ambulance systems operating, it will mean fewer ambulances, longer response times, and greater reliance on our already strained local taxpayers. We urge CMS to withdraw the proposed limitation or provide a broad exemption that protects the essential readiness functions of the fire service and rural public EMS providers. - Mendocino County Fire Chiefs Association