CMS releases alternate care site payment resource

On May 26, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a fact sheet regarding payment for care in hospital alternate care sites (ACSs). The fact sheet details the steps necessary to be eligible for CMS reimbursement.

It should be noted that the fact sheet details the following definitions:

• ACS = These sites are often called “alternate care sites” (ACSs), but may also be referred to as “temporary expansion locations,” “temporary expansion sites,” “field hospitals,” or by other names.
   
• “State and local governments” is used in this fact sheet to account for state, city, county, territorial and tribal governments and their respective agencies, including health departments.

The fact sheet provides some key takeaways such as the easiest path to obtaining payments through CMS programs for covered health care services furnished at an ACS. These key takeaways are:

1. Hand over operation and billing for care delivered in the ACS to an enrolled hospital or health system;
2. Enroll the ACS as a new hospital in CMS programs; or
3. If options (1) and (2) are not available, CMS would not make facility payments, but qualified and enrolled physicians or other non-physician practitioners could bill for covered (professional) services that they furnish at the ACS.

There are three questions CMS uses to determine whether it will pay for covered hospital facility inpatient or outpatient services furnished to enrolled beneficiaries at an ACS.

1. Is the ACS operator already enrolled in CMS programs as an acute care hospital or other provider type that is able to furnish inpatient or outpatient care during the PHE? 
2. Is the ACS operator contributing resources and responsible for the care being furnished to CMS beneficiaries at the ACS? 
3. Is the ACS operator following the billing requirements of the applicable Medicare, Medicaid, or CHIP hospital payment system? 

Some state and local governments have also requested HHS deploy portable medical facilities called Federal Medical Stations, and provide clinical staff through the National Disaster Medical System. The Federal Healthcare Resiliency Task Force has published a guide to the funding opportunities organizations can seek to establish and operate ACSs.

Regarding ACSs that are established in a multi-hospital/organization approach the fact sheet states that they should contact their CMS Regional Office if they are interested in being paid by Medicare or Medicaid for hospital services furnished to Medicare or Medicaid beneficiaries at the site. Under this scenario, where more than one hospital or health system operates the ACS, CMS would need additional information to determine whether it could pay for services at that location. A full list of CMS Regional Office contacts is available in the fact sheet Appendix D.

Finally, the fact sheet notes that since these ACSs are considered extensions of a “brick and mortar,” under federal law, they must meet CMS requirements in order to bill Medicare or Medicaid for covered inpatient or outpatient hospital services furnished to Medicare or Medicaid / CHIP beneficiaries. Therefore, Conditions of Participation, Enrollment and Billing Rules along with 1135 waivers all apply to ACSs being operated as an extension of a hospital organization.

For more details see the fact sheet.