We respectfully ask that HB 1115 be carried over and worked on through a stakeholder work group including ambulance and medical transport providers, hospitals, and consumer representatives before any further action is taken. As drafted, the bill raises patient-safety and system-performance concerns that would benefit from collaborative clarification and practical guardrails.
American Medical Response (AMR) employs over 500 EMTs and paramedics and has a strong statewide presence in Virginia, working with major health systems including Bon Secours/Mercy Health, HCA Healthcare, VCU Health, VHC Health, Inova, and Riverside Health. AMR is part of Global Medical Response, the nation’s largest air and ground emergency medical services provider.
At a high level, HB 1115 conflates clinical dispatch and medical necessity with retail-style price disclosure. Medical transport is not a retail transaction. The appropriate level of service, clinical interventions, equipment, mileage, and medical necessity are often determined only after patient contact. Requiring pre-service disclosure of “all fees and charges” would force providers to offer estimates that are inherently uncertain and highly dependent on individual insurance coverage, leading to confusion and disputes without meaningfully improving transparency.
More concerning, forcing price discussions at the point of care introduces friction between providers and patients. Ambulance crews could be placed in the position of discussing fees at the bedside or on scene, potentially leading some patients to refuse medically appropriate transport and creating avoidable risk when care is delayed or foregone. HB 1115 also risks pulling EMTs and paramedics into financial conversations that do not belong at the bedside. These clinicians are trained to assess, stabilize, and make time-sensitive medical decisions—not to estimate charges or interpret insurance benefits.
These concerns are magnified for patients experiencing behavioral health crises or those with cognitive impairment or legal incapacity, where point-of-care financial disclosures are impractical and destabilizing. The bill also introduces new administrative steps that increase on-scene and pre-departure time. In a system where staffed ambulances are scarce, added administrative burdens reduce 911 and interfacility transfer availability and degrade system performance. For interfacility transfers, delays can jeopardize accepted beds at receiving facilities and prolong hospital boarding.
Finally, HB 1115 does not align with how insurance coverage and reimbursement actually work. Many transports are covered by Medicare, Medicaid, or contracted commercial plans, with patient responsibility determined only after claims adjudication. Mandating pre-service disclosure of final amounts risks misleading patients about their true financial obligation.
We support a workable, patient-centered approach to consumer protection that improves clarity and fairness without reducing access to medically necessary transport or diverting scarce clinical resources from patient care. For these reasons, we respectfully request that HB 1115 be carried over and refined through a stakeholder work group before further legislative action is taken.
We respectfully ask that HB 1115 be carried over and worked on through a stakeholder work group including ambulance and medical transport providers, hospitals, and consumer representatives before any further action is taken. As drafted, the bill raises patient-safety and system-performance concerns that would benefit from collaborative clarification and practical guardrails. American Medical Response (AMR) employs over 500 EMTs and paramedics and has a strong statewide presence in Virginia, working with major health systems including Bon Secours/Mercy Health, HCA Healthcare, VCU Health, VHC Health, Inova, and Riverside Health. AMR is part of Global Medical Response, the nation’s largest air and ground emergency medical services provider. At a high level, HB 1115 conflates clinical dispatch and medical necessity with retail-style price disclosure. Medical transport is not a retail transaction. The appropriate level of service, clinical interventions, equipment, mileage, and medical necessity are often determined only after patient contact. Requiring pre-service disclosure of “all fees and charges” would force providers to offer estimates that are inherently uncertain and highly dependent on individual insurance coverage, leading to confusion and disputes without meaningfully improving transparency. More concerning, forcing price discussions at the point of care introduces friction between providers and patients. Ambulance crews could be placed in the position of discussing fees at the bedside or on scene, potentially leading some patients to refuse medically appropriate transport and creating avoidable risk when care is delayed or foregone. HB 1115 also risks pulling EMTs and paramedics into financial conversations that do not belong at the bedside. These clinicians are trained to assess, stabilize, and make time-sensitive medical decisions—not to estimate charges or interpret insurance benefits. These concerns are magnified for patients experiencing behavioral health crises or those with cognitive impairment or legal incapacity, where point-of-care financial disclosures are impractical and destabilizing. The bill also introduces new administrative steps that increase on-scene and pre-departure time. In a system where staffed ambulances are scarce, added administrative burdens reduce 911 and interfacility transfer availability and degrade system performance. For interfacility transfers, delays can jeopardize accepted beds at receiving facilities and prolong hospital boarding. Finally, HB 1115 does not align with how insurance coverage and reimbursement actually work. Many transports are covered by Medicare, Medicaid, or contracted commercial plans, with patient responsibility determined only after claims adjudication. Mandating pre-service disclosure of final amounts risks misleading patients about their true financial obligation. We support a workable, patient-centered approach to consumer protection that improves clarity and fairness without reducing access to medically necessary transport or diverting scarce clinical resources from patient care. For these reasons, we respectfully request that HB 1115 be carried over and refined through a stakeholder work group before further legislative action is taken.