CMS waiver for hospital-at-home designed to address COVID-19-driven capacity issues | HFMA

• CMS quietly expanded the “Hospital Without Walls” initiative. It hosted an informational webinar “Acute Hospital Care at Home” on Dec. 1.
• The initiative makes available a waiver of the Medicare Conditions of Participation that nursing services be provided on premises 24/7 and requires the immediate availability of a registered nurse for the care of any patient.
• This is not a blanket waiver but will allow individual qualifying hospitals to receive inpatient payment for providing acute level services to Medicare beneficiaries in their homes.

CMS quietly expanded the “Hospital Without Walls” initiative in early December by:

• Making available a waiver of the Medicare Conditions of Participation that nursing services be provided on premises 24/7.
• Requiring the immediate availability of a registered nurse for the care of any patient.

CMS hosted a  informational webinar “Acute Hospital Care at Home” on Dec. 1,  providing details about the initiative.

This is not a blanket waiver but will allow individual qualifying hospitals to receive inpatient payment for providing acute level services to Medicare beneficiaries in their homes. The waiver covers 60 acute conditions like asthma, CHF and COPD. Beneficiaries will only be admitted to a home hospitalization from emergency departments or an inpatient bed. In instances where the patient is admitted to a home hospitalization from an inpatient bed, it will be considered an intra-facility transfer and will not impact payment (e.g., does not trigger a transfer MS-DRG). Hospitals that qualify for the waiver will be paid the full MS-DRG payment.

Hospitals must deliver the following services to a Medicare beneficiary who receives acute level services in the home:

• A once daily in-person visit with an MD or APP (may be face-to-face or virtual).
• A once daily in-person visit with a RN (may be face-to-face or virtual).
• At least two daily visits from a provider. This requirement may be satisfied using a qualified home paramedicine program.

Additionally, there must be immediate connection 24/7 to a physician or a nurse and the capability for an emergency response within 30 minutes. As part of the waiver application process, hospitals will have to demonstrate how they will provide services to meet the following needs: pharmacy, infusion, respiratory care including oxygen delivery, diagnostics (labs, radiology), monitoring/vitals, transportation, food services, DME, PT/OT/ST, and social work and care coordination (including safe and seamless patient discharges).

There are separate waiver applications for hospitals with experience (treated more than 25 patients in a hospital-at home program) with the hospital-at-home model and those without.

While experienced hospitals will only need to attest to possessing key capabilities, inexperienced hospitals will need to provide details as to how they will meet key program requirements. Six health systems — Brigham and Women’s Hospital in Massachusetts, Massachusetts General Hospital, Huntsman Cancer Institute in Utah, Mount Sinai Health System in New York City, Presbyterian Healthcare Services in New Mexico and UnityPoint Health in Iowa — have been granted the wavier to deliver hospital at home for Medicare beneficiaries. CMS has made a list of FAQs and resources available.

Takeaway

While it’s been rumored that the Center for Medicare & Medicaid Innovation (CMMI) was working on a hospital-at-home model, this is a short-term waiver designed to address COVID-19-driven capacity issues. CMS has been clear that, much like many of the telehealth provisions, when the PHE expires, so does the waiver (and the ability to get paid the full MS-DRG payment for acute services provided to Medicare beneficiaries in their homes).

However, it’s very likely that CMMI will incorporate the data and lessons learned from the pandemic into a future hospital-at-home program. This could potentially accelerate the development of a CMMI hospital-at-home model for Medicare fee for service beneficiaries after the pandemic.