During this crucial time it is important to insure your continued ability to be reimbursed from CMS once the pandemic settles and you are trying to recover and get back to normal operations. When alterations are made to your facilities and/or you need to use alternate facilities (a tent outside the ED for example) you may not be meeting the requirements of the Conditions of Participation (CoP).  By not meeting these requirements you can possibly lose your ability to bill for reimbursements through the Medicare and Medicaid programs. CMS has issued a few blanket waivers that cover many clinical type issues, and many states have been  approved for waivers through the 1135 waiver process covering specific needs. 

However they do not cover many of the physical plant items such as the inability to complete required fire, utility, and/or medical equipment testing for varied reasons, etc. Whether you use a blanket waiver provided, an approved state 1135 waiver, and/or the hospital acquired 1135 waiver process, it is critical to keep detailed documentation, and keep your Emergency Command Center operating throughout the event.     

If you need assistance sifting though what is covered under blanket or state approved waivers, what you may need in order to request an 1135 waiver through the SSA program, what needs to be documented, or assistance completing any of the required actions, please do not hesitate to contact us for guidance and assistance.     

For a link to CMS blanket waivers:   

https://www.medicaid.gov/state-resource-center/disaster-response-toolkit/federal-disaster-resources/?entry=54036

For Link to State Waivers approved:

 https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers