December 2, 2020

Sometimes you have to think outside the box.  When it comes to addressing the large influx of COVID patients needing life-sustaining treatment, government and healthcare leaders have done just that.  Early on in the pandemic of 2020, the Centers for Medicare and Medicaid Services (CMS) and the Department of Health and Human Services (HHS) issued multiple waivers that allowed hospitals new and unprecedented latitude in caring for these patients, including the concept of off-site services.

A New Paradigm

Since we are in the midst of a second wave of COVID-19, it may be a good time to revisit some of these government allowances as they pertain to the issue of site of service.  In November, CMS provided an updated document outlining place of service options that are available to hospitals during the public health emergency (PHE).  The agency, which falls under the jurisdiction of HHS, explained that these temporary provisions are meant to fulfill its “Hospitals Without Walls” initiative—an effort to allow off-site locations for care events that would nonetheless act as extensions of the hospital setting.

According to the November update, hospitals can provide services in facilities that would not normally be deemed to be part of the hospital.  Specifically, the document states:

CMS is providing additional flexibilities for hospitals to create surge capacity by allowing them to provide room and board, nursing, and other hospital services at remote locations or sites not normally considered parts of healthcare facilities, such as hotels or community facilities. This flexibility will allow hospitals to separate COVID-19 positive patients from other non-COVID-19 patients to help efforts around infection control and preservation of personal protective equipment (PPE).  For example, for the duration of the COVID-19 PHE, CMS is allowing hospitals to screen patients at off-site locations, and furnish inpatient and outpatient services at temporary expansion sites.  Hospitals would still be expected to control and oversee the services provided at an alternative location.  

However, the government doesn’t stop there.  According to a later November FAQ document published by CMS, we find the following language:

Under the CMS [interim final rule with comment (IFC)] published in the Federal Register on May 8th, CMS is temporarily expanding the extraordinary circumstances relocation exception policy during the PHE to include both on-campus and excepted off-campus [provider-based departments (PBDs}] that relocate (or partially relocate) to new off-campus locations, including to any temporary expansion locations (such as other sites or the patient’s home, as applicable), due to the PHE. This policy applies to relocations occurring on or after March 1, 2020 (85 FR 27560) and will last until the end of the PHE. Further, CMS is streamlining the process for relocating PBDs to seek an exception, and will allow PBDs to immediately begin furnishing and billing for services at the new location while the regional office is reviewing the exception request.

Expanding on An Idea

Not satisfied with these measures, CMS published yet another rule change last week, allowing for further exceptions in hospital service locations.  As reported by Healthcare Dive (HD), the primary elements of the late November rule include the following:

• The ability of hospitals to treat their acute care patients at home ahead of an expected surge in COVID-19 hospitalization following the Thanksgiving holiday will be expanded.  This is due to an expectation that many Americans will have “ignored public health advice against gatherings.”
• The guidance released last week also tweaks earlier changes allowing ambulatory surgical centers (ASCs) to provide greater inpatient care by stating 24-hour nursing services need to be available only when a coronavirus patient is at the center.  At least 85 ASCs are already providing inpatient care, and more are likely be pulled in to such utilization.
• Six health systems were immediately granted waivers for the new Acute Hospital Care At Home program to treat more than 60 acute conditions. CMS said it has been in discussion with other hospitals and expects new applications to be submitted.

Essentially, the new guidance “focuses on at-home care for conditions that can often warrant a hospital stay, like asthma, pneumonia, congestive heart failure and chronic obstructive pulmonary disease.”

The HD article stresses that patients can only be admitted for at-home acute care from an emergency room or inpatient bed, and they must receive “at least two in-person visits a day from a registered nurse or paramedic.”  Hospitals will also be required to “perform screening for non-medical factors that could impede at-home care like not having working utilities or a risk for domestic violence.”

The full CMS press release related to these most recent changes to hospital surge locations can be found at the following link: CMS Announces Comprehensive Strategy to Enhance Hospital Capacity Amid COVID-19 Surge | CMS.  At MiraMed, it is our privilege to bring timely information to your attention—especially during these extraordinary times of change.  We hope these articles will assist you in your short- and long-term planning.  If we can help you from a business solution standpoint, please don’t hesitate to reach out to us at info@miramedgs.com.