Rule status: Proposed
Comment by date: November 2, 2020
Rule Full Text
The Fire Department is proposing to revise the amounts it charges patients and insurers for Emergency Medical Service (EMS) ambulance treatment and/or transport service provided through the New York City 911 System, to reflect increased costs and help defray the City’s cost of providing these services.
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November 2, 2020
11:00am - 12:00pm EST
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Online comments: 1
Statement of Daniel Burstein regarding the proposed FDNY changes in rates,
as per: 4900-02-ambulance-rates-9-24-20-publication-final.pdf
via web page upload (see first paragraph)
Before I get to my comments I’d like to point out that the FDNY-Direct URL listed in the publication seems to be wrong and leads to error messages. I’ve tried various permutations and none seem to work.
Note that I’d have preferred to comment in person, but fully understand all too well the issues with the pandemic.
The first point I’d like to make is my very serious discomfort with the entire concept of FDNY charging for EMS service.
When people in NYC call 911 for a police or a firefighting response, it is very rare for the agencies to prepare a bill.
It’s way beyond time for NYC to reconsider this whole economic picture.
The second point I’d like to make is that there is no advance notice to the patient or family that they are going to be billed. This is at odds with just about all other products and services that people deal with everyday.
If I bring clothes to the dry cleaner, the store will have a price list that provides a pretty decent estimate of what I’ll be paying. Even car repair shops will tell us what to expect when dropping off a vehicle for repair.
Why does the EMS division of FDNY, and for that matter, why does the City of New York, believe itself to be exempt from basic consumer protection laws?
This is about to become even more problematic if, as FDNY is proposing, they implement a fee for “treatment in place”. This is a MAJOR change in the historical nature of NYC’s EMS billing, and therefore highlights that there’s no price list ahead of time.
The final issue I’d like to bring up is one of the great secrets of the NYC 911 EMS system, namely that A THIRD of the calls for EMS assistance get turfed over to outside contractors.
These groups and their personnel, while generally every bit as dedicated and professional as the NYC folk, are NOT operated by FDNY.
As such, under the current arrangement, they can set up their own rate cards and charges, which are often significantly higher than the ones used by NYC.
And again, this is not divulged to the 911 caller. In fact, the person reaching out for assistance has no way of knowing whether they’ll get a NYC crew or whether they’ll be getting a third party, and similarly has no way of specifying any such preference.
There are certainly many other issues with this policy, but for today I simply want to point out the very curious billing arrangements.
Again, in most consumer transactions, the purchaser is provided a realistic estimate ahead of time.
In the FDNY EMS universe, not only doesn’t this apply, but the patient may encounter totally different rate charts depending on just which type of EMS response unit is sent out.
In the vaguely analogous situation of calling “911” for a tow truck, the NYC NYPD dispatchers send out either an “authorized tow” if on a highway, or a “rotation tow” if a local street.
And despite these being independent operators, they all work from the same rate sheet as established by the Department of Consumer Affairs.
I’d suggest it’s way beyond time that NYC made a similar and singular price card for all the EMS units it dispatches?
Thank you for your time.
New York, NY 10027