Be a Storyteller: A Three-Step Advocacy Playbook
Written By: Alexandra Hembrough, Esq., General Counsel, Solutions Group Services
Every advocacy campaign is, at its heart, a story. Every advocacy campaign is, at its heart, a story. While this article will focus on the story-telling technique from the lens of an ambulance provider, this framework applies no matter what area of healthcare services you are in or that you provide.
The story an ambulance provider tells about the cost of readiness, the acuity of the patients it moves, and the risk it absorbs on every call is the story that legislators, regulators, and payers ultimately act on, or ignore. Right now, the EMS industry has an unusually good story to tell, and an unusually important moment to tell it in. The Reimbursing Emergency Services for Critical Urgent Encounters Act (the “RESCUE Act”) has put ambulance reimbursement back on Congress’s radar for the first time in a long time, and the conversation it has triggered, especially for those providers doing a lot of interfacility transports, is happening in your local and state legislative and payer offices as much as it is in Washington. We want to give you our recommendations on how to engage in that conversation, and, just as importantly, how to make sure your own house is in order before you tell your story to anyone else.
A Bit of History: Why This Moment Matters
The Medicare Ambulance Fee Schedule has not been meaningfully updated since it was implemented in 2002, and the cost data underlying it dates back to 1998. A 2024 RAND Corporation study prepared for CMS found that, on average, ambulance agencies are paid more than $1,500.00 less per transport than their actual cost of providing that transport, a gap that hits rural and interfacility providers especially hard. The RESCUE Act, introduced on a bipartisan basis in July 2026, would require CMS to rebuild that formula around current, actual cost data and update it on a recurring cycle going forward.
At the same time, CMS is still absorbing the recommendations of the 2024 Ground Ambulance and Patient Billing Advisory Committee (GAPBAC) Report, chaired by our very own, Asbel Montes, and delivered to Congress with its recommendations on preventing balance billing, improving fee disclosure, protecting patients in ground ambulance transports, and, most important to this discussion, clarifying certain definitions such as “Emergency” in the context of a ground ambulance transport or interfacility transport. A growing number of states have already begun to enact many of the GAPBAC Report recommendations and agreed-upon definitions into their own ambulance, balance-billing, and disclosure statutes, and the industry should be paying close attention to those states that have already made change and begin formulating a plan to make similar updates in their own local or state environments.
Asbel recently started an article series that, in our view, is the easiest, plain-English on-ramp into understanding this moment for an operations or compliance team that does not live in Medicare payment policy every day. We recommend starting here. The series, so far, walks through: (1) what the RESCUE Act actually does and does not do; (2) what “rebasing” the fee schedule really means, it is not simply “more money,” but a structural shift from a decades-old, labor/non-labor cost proxy to a system anchored in current, verifiable cost data; and (3) why the definition of an “emergency,” particularly as applied to an emergency interfacility transport, is quietly one of the most consequential open questions in the entire reform conversation, because it determines which transports get evaluated under which payment and coverage rules in the first place. He will continue to expand on these topics in more detail as the series continues, with thought provoking questions and actionable insights for you and your organization.
The Three-Step Advocacy Process We Recommend
Step 1: Read the Source Material
Before your organization says anything publicly, make sure the people doing the talking have actually absorbed the material. Work through Asbel’s article series, and stay up to date on new articles being released in the series, as a leadership team, not individually. Each piece will build on the last, and your advocacy efforts will not land correctly if your team has not first internalized what rebasing is trying to fix and how certain definitions apply to your organization, especially those providing a lot of interfacility transports. The goal is to have a shared, accurate vocabulary before anyone drafts a letter or sits down with a legislator or payer to attempt to come to a mutual agreement or understanding.
Step 2: Choose the Right Messenger for the Right Message
One of the most common advocacy mistakes we see is putting the wrong voice in front of the wrong audience, even with the right message. Not every part of this story should be told by the same person, and legislators and regulators are increasingly good at spotting a mismatched messenger. Further, the right messenger will look different depending on the type of organization you represent:
Governmental Providers: Your pricing and cost information is already open to the public and subject to scrutiny. The most effective advocacy starts with educating your community on where to find that information, how to read it, and what to pay attention to.
Non-Profit Providers: As a tax-exempt organization, you already file an annual IRS Form 990 – a public record of your revenue, expenses, and compensation. Educate your community on where to find these filings, how to access them, and how to read them so they understand how your costs translate into your pricing for services.
For-Profit Providers: Your storytelling will look entirely different. Your costs and pricing are not open to the public, so your board of directors must have candid internal conversations about how – and, just as importantly, who – should tell that story transparently. Your own medical director or executives may not be the right choice in every instance; their insight, however accurate, can read as self-serving simply because of their association with your organization. The right messenger should be disconnected from your organization but still understanding it. Look for outside champions: an independent emergency physician who understands EMS to speak to level-of-care and medical-judgment questions, or a trusted attorney well-versed in healthcare law, from outside your organization, to speak to legislative gaps and ambiguities that create room for error or abuse. These voices carry weight precisely because they have no financial stake in your organization’s outcome, and their independent standing is what will hold you state and local legislators’ attention.
Matching the message to the messenger is not a public-relations nicety; it is what gives your advocacy credibility with an audience that is used to hearing only one version of this story from the industry.
Step 3: Engage at the State and Local Level
Federal reform sets the frame, but most of the actual leverage over these issues lives at the state and local level. The GAPBAC Report provides a useful roadmap here: it catalogs how states have already begun adopting disclosure requirements, out-of-pocket caps, and network-adequacy rules for ground ambulance services, and it gives you a sense of where your state currently sits relative to its neighbors. We recommend using the report as a checklist, and then:
Identify whether your state legislature, insurance department, or Medicaid agency has an open rulemaking, study committee, or pending bill touching anything related to these topics, ambulance reimbursement, balance billing, or the definition of medical necessity/emergency, etc., and get on the record early, not after language is drafted.
Build relationships with your state EMS association and state ambulance association chapters before you need them; coordinated industry testimony carries more weight than a single company’s letter.
Bring local data. Legislators respond for more to what rebasing means for the ambulance service covering their own district than to a national statistic.
Loop in local hospitals, skilled-nursing partners, and other physicians on the interfacility side, they are directly affected by how “emergency” interfacility transports get defined and reimbursed, and their voice alongside yours strengthens the story.
We are happy to help you talk through where your state or local government currently stands and how to plug into the right conversations and groups.
A Word of Caution: Don’t Spin Your Story Until You Have All the Facts
That inward look also cannot be a one-time exercise. In our recent nControl audit results, we have seen how quickly performance can shift as staffing, processes, and workflows change. Even organizations that have historically performed well can experience meaningful declines or new areas of risk when those changes create ripple effects across the revenue cycle.
That is exactly why we developed nControl as an ongoing, independent way to validate what is happening across the full lifecycle of a claim. A strong result at one point in time does not necessarily reflect where an organization is today. Regular review helps identify changes early and gives leadership confidence that the story they are telling legislators, regulators, and payers is supported by their current practices and current data. Reach out to us at connect@solutionsgroup.comfor more information.
An organization that is publicly advocating for a more accurate, cost-based reimbursement system, or for a clearer definition of “emergency,” needs to be able to withstand the obvious follow-up question: are you practicing what you preach?
Don’t spin your story until you have all the facts. Get your internal house in order first, then tell your story.
