A clear-eyed look at CPE, IGT, and provider tax programs—and how to protect your agency’s budget now.
There’s no siren when a funding stream disappears. No alarm sounds when CMS quietly redefines which costs are reimbursable under Medicaid. But if you’re relying on Medicaid supplemental payments, whether through CPE, IGT, or provider tax, you need to know what recent legislation means for your agency’s budget and future.
A Small Slice of the Medicaid Pie, But a Big Impact
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law, introducing sweeping changes to tax, energy, and entitlement policy. One major provision is a $1 trillion cut to Medicaid over the next decade, driven by new eligibility restrictions, work requirements for enrollees, and limits on Medicaid financing plans, also known as supplemental payment programs. These cuts raise concern for EMS providers in more than 30 states who rely on supplemental payments for critical revenue. While some impacts are obvious, others will vary depending on the type of program in use within each state.
At Digitech, we’ve seen the confusion firsthand. EMS leaders across the country are trying to make sense of the patchwork of Medicaid supplemental payment programs in play. And we get it. The alphabet soup is dense, and the funding rules vary by state. But understanding how these programs work is important, especially now. EMS receives just a fraction of what hospitals take in through supplemental payments — less than $500 million annually, by our estimates (as no aggregated numbers exist for EMS), compared to $94 billion for hospitals in FY 2022.[1] The impact on EMS is outsized in relation to this small piece of the federal spending puzzle. For many overworked, chronically underfunded systems, these dollars aren’t extra. They’re critically important to the viability of EMS.
How State Dollars Unlock Federal EMS Funding
Despite their different names and acronyms, all EMS supplemental payment programs work in a similar way: they use state funds to pull down federal matching dollars. Because Medicaid is a joint state-federal program, for every dollar a state “spends,” the federal government provides a matching percentage—anywhere from 50% to 77%, depending on the state’s per capita income. (States with lower income levels get a higher federal match.[2]) This core funding structure is what makes supplemental payments possible and why changes to the rules at either level can directly impact EMS budgets.
The Common Thread in All EMS Supplemental Programs
Similarly, Medicaid programs are jointly administered by the federal and state governments. Any changes provider payments or covered services at the state level needs federal approval. The OBBBA brings some of the most significant shifts we’ve seen in Medicaid financing in decades, and that includes the supplemental payment programs many EMS providers have depended on for a decade or more. If your agency relies on these dollars to keep units staffed and ready, expect changes ahead.
Three Paths to Supplemental Medicaid Payment
Before we dive into the possible impact of restrictions or changes that the OBBBA may bring to Medicaid supplemental payments, it’s important to understand the three main types of these programs commonly used by EMS agencies:
- Certified Public Expenditure (CPE): Used by government agencies, this model allows providers to report the actual cost of delivering Medicaid-covered ambulance transports. As allowed through a State Plan Amendment approved by CMS, an eligible EMS entity may voluntarily certify public funds spent to support the cost of providing a Medicaid-covered service (e.g., ambulance transport). CPE programs can go by many names, including Ambulance Services Supplemental Payment Program (ASSPP), Emergency Service Transporter Supplemental Payment Program (ESPP), Ground Emergency Medical Transport (GEMT), Public Emergency Medical Transport (PEMT), amongst others.
- Intergovernmental Transfer (IGT): In an IGT program, a local government entity (like a city or county EMS agency) transfers funds to the state Medicaid agency before a Medicaid payment is made. The state agency then uses this money to draw down federal match. The combined funds are returned to providers as supplemental payments. Each state makes its own decisions, within federal requirements, regarding how to finance its share of the Medicaid program. Generally speaking, these are often linked to State Directed Payments (SDPs) and used to support Medicaid Managed Care transports. The enhanced payments may be established at statewide average cost, Average Commercial Rate (ACR), or Medicare.
- Provider Assessment (Tax): Unlike CPE or IGT, this is a broad term for a program that funds State contributions toward Medicaid healthcare expenditures in order to secure matching federal funds. Provider taxes may benefit both governmental and private EMS agencies, depending on regulation and CMS approval. To qualify, the taxes must be broad-based and uniform – levied at the same rate across all providers in a class, and providers cannot be held harmless (direct/indirect guarantee that each provider will be repaid for the amount of taxes paid). There’s a federal “safe harbor” if the tax stays below 6% of net patient revenue; the indirect guarantee does not apply if the tax rate falls at or below the safe harbor limit.
Medicaid Supplemental Payment Programs at a Glance
Type of Program | Certified Public Expenditure (CPE) | Intergovernmental Transfer (IGT) | Provider Assessment (Tax) |
Entities Eligible | Governmental | Governmental | Governmental, nonprofit, and for-profit (private) |
Reporting Requirements | Annual cost report | Cost report or average commercial rate survey | Net patient revenue report |
Medicaid Payment Delivery Systems Covered | Typically, Medicaid FFS (in Texas, CPE is utilized for uninsured charity care reimbursement only) | Typically, Medicaid MCO but may also be utilized for Medicaid FFS | Medicaid FFS and Medicaid MCO |
Approvals Needed | State Plan Amendment (SPA) | CMS preprint | Typically, state legislation and CMS preprint |
Frequency of Approvals | Once approved, remains in effect until amended | Must be re-approved annually/biennially | Must be re-aproved annually/biennially |
Audit/Desk Review Requirements | Yes | No | No |
Now that we’ve defined the three programs, we move on to how these programs work.
CPE: How It Works and Where It Falls Short
In CPE programs, participating agencies submit detailed annual cost reports to document the true cost of providing ambulance transports to Medicaid patients.
How it works: If your agency calculates an average transport cost of $2000 and the Medicaid allowable (interim payment already received) is $200, the $1800 difference becomes eligible for reimbursement. Assuming a 50/50 state-federal match, you’d be eligible to receive $900 in federal funds. But there are three key limitations:
- A CPE is only available for governmental providers.
- Only Medicaid Fee-for-Service transports are eligible for reimbursement under a CPE. If your state has transitioned most enrollees to Medicaid Managed Care through a managed care organization (MCO), the funding opportunity through a CPE can be very limited.
- Cost reporting introduces administrative overhead on the state and participating providers to maintain CMS compliance. This can be a significant burden.
Not sure how much of your Medicaid population is covered by FFS vs. MCO? Check with your billing vendor. You can also get a rough estimate at kff.org.[3] They estimate that the national average is around 75%.[4]
IGT: Filling in the Gaps in Managed Care States
While traditional CPE programs work well in states that have a majority of their claims covered by FFS, an IGT-based supplemental payment program may be layered on to cover costs related to Medicaid MCO transports.
In this scenario, a governmental EMS provider sends funds to the state Medicaid agency, which then uses those dollars to draw down federal matching funds. The combined funds (local and federal) are distributed back to the participating providers as supplemental payments. States may use IGT programs based on average statewide costs (which requires cost reporting) or Average Commercial Rates (ACR). But these programs require formalization and an annual CMS approval to remain in place, making them more vulnerable to policy shifts.
Provider Tax Programs: Broader Access, Different Rules
Unlike CPE and IGT, provider assessment (tax) programs are available to ALL EMS agencies, including governmental, nonprofit and private for-profit. Under this model, EMS agencies are taxed based on a formula tied to transport number or percentage of revenue. The state uses those funds to draw down federal matching funds, which are then redistributed to providers in the form of enhanced payments. Providers receive supplemental payments proportional to their Medicaid transport volume, making this a potentially meaningful funding stream for high-volume providers.
Policy Impact: What Does the OBBBA Mean for EMS Supplemental Payments?
CPE Under the Microscope
The OBBBA doesn’t appear to directly target CPE programs, but they are under CMS scrutiny in terms of its interpretation of what counts as reimbursable costs for Medicaid patient transports. Historically, agencies could include readiness costs (staffing, ambulance maintenance, administrative support) in addition to the actual response cost and clearing the hospital. CMS is challenging that readiness piece. In some states like Texas, CMS audits have already excluded readiness costs, restricting the allowable cost to the time when the ambulance crew first comes in contact with a patient to when the patient is dropped at the hospital. This shift ignores the 24/7 readiness that is essential to serving Medicaid patients, even if the clock doesn’t start until patient contact. Without those substantial expenditures, the Medicaid patient could not call 911, receive immediate treatment, and be transported to the hospital. If readiness is excluded, local taxpayers will likely be left to fill the funding gap.
IGT: High Risk, Fast Changes
IGT programs are vulnerable to quick federal changes. CMS could decide to cap allowable costs (reimbursement) at the Medicare rate, which would lower supplemental payments, in many cases substantially. Because IGT programs require annual CMS approval, changes can happen fast with little time for agencies to adjust.
Provider Tax: Uncertain but Tightening
Nearly every state uses provider assessments for at least one provider class (49 out of 50, with only Alaska as the exception), whether that’s hospitals, EMS, nursing facilities, or others. This is why any cuts to provider assessments are an important issue. The ripple effects go far beyond EMS, impacting multiple parts of the healthcare system.
The OBBBA’s impact on provider tax programs is less clear and may vary by state, but CMS has already signaled that changes are coming. Most likely, we’ll see freezes on assessment increases, limits on new programs, and tighter rules for existing ones.
From our work with EMS agencies across the country, we believe provider assessments are the most likely target for significant federal scrutiny. Not only has the OBBBA highlighted them, but CMS has also proposed new rules aimed at closing loopholes in how these programs operate (link to rule).
States that rely heavily on provider assessments to supplement Medicaid funding—particularly those with large Medicaid populations such as Kentucky, Missouri, and Tennessee—should prepare for possible revenue contraction. One lesson from recent experience is that regulatory changes often cause the most harm because of the uncertainty and lag time. You don’t feel the impact right away; it can take months before reduced payments are reflected in your reports and budget. At that point, replacing the lost revenue becomes extremely difficult.
In Texas, for example, Digitech and our clients have had to navigate significant changes to the Ambulance Services Supplemental Payment Program (ASSPP) after cost reports were submitted. New cost allocation and data reporting requirements, likely tied to a federal OIG audit, were implemented midstream, creating delays, confusion, and making it impossible for providers to budget accurately.
We recommend running worst-case scenario models now and factoring in the possibility of delayed or reduced payments. For high-volume Medicaid providers in states that depend on provider assessments, this is a “double whammy” risk. As Medicaid enrollment drops due to new eligibility restrictions, you may face both increased uncompensated care and reduced supplemental funding.
Act Now to Protect Your EMS Funding Future
Given federal spending changing substantially and Medicaid rules tightening, EMS agencies need a clear understanding of which supplemental payment programs they use and how each could be impacted as changes take effect. The exact impacts are still uncertain, as broad legislation like the OBBBA must be interpreted, implemented, and potentially altered over time.
Now is the time to review your funding streams, run scenarios, and start conversations with state partners and local decision-makers. These changes may roll out gradually, but agencies that understand their exposure and plan ahead will be in the strongest position to protect service levels and budgets.
Digitech encourages you to reach out to our Medicaid supplemental payment program experts if you want to discuss this situation in more detail. Talk to us now to understand the potential impact on your agency:
- Email Michael: mbrook@digitechcomputer.com
- Email David: dmead@digitechcomputer.com
1. MACPAC (Medicaid and CHIP Payment and Access Commission) Issues Brief, April 2024
2. Kaiser Family Foundation federal and State Share of Medicaid Spending, FY 23
3. KFF.org. State Health Facts: Share of Medicaid Population Covered under Different Delivery Systems
4. Utilizing 2022 data, Kaiser Family Foundation estimated 75% of Medicaid recipients are enrolled through Managed Care plan. See 10 Things to Know About Medicaid Managed Care by Elizabeth Hinton and Jada Raphael. Published: Feb 27, 2025