Member Article

The Centers for Medicare & Medicaid Services hasrecently announced an unprecedented “Hospitals Without Walls” program to aid in the fight against COVID-19.

The goal of this program is to ensure that local hospitals and health systems have the capacity to handle a potential surge of COVID-19 patients through temporary expansion sites including other, non-affiliated healthcare providers and even unlicensed locations such as community centers and schools.

Included in the array of regulatory waivers is a temporary condition of participation waivers that would allow Ambulatory Surgery Centers (ASCs) to convert to hospital status and provide hospital services in order to aid in the fight against the pandemic so long as such conversions would not be inconsistent with applicable state emergency response plans. The original, limited guidance called for ASCs to complete the conversion by reaching out to their Medicare Administrative Contractor (MAC) and completing an attestation.

On April 3, CMS released new, more detailed conversion guidance to the State Survey Agencies. The conversion process as set forth in the new guidance is as follows:

Medicare-certified ASCs wishing to enroll as a hospital must first notify the MAC serving its jurisdiction of the ASC’s intention to convert to hospital status.

• The ASC will be asked by the MAC to submit the signed attestation statement included with the guidance and attached here.
• The MAC will forward the signed attestation statement to the appropriate CMS Regional Office.
• Within two days, the CMS Regional Office will review survey information to determine whether the ASC was placed on Immediate Jeopardy (IJ) status within the previous three years.
• If no IJ-level deficiencies were found in the previous three years, or if IJ-level deficiencies were found but subsequently removed through the normal survey process, the CMS Regional Office will: (1) review and approve the attestation statement; (2) create a new facility profile and certification kit in the Automated Survey Process Environment (ASPEN) and assign a hospital CMS Certification Number (CCN); and (3) send a tie-in notice as a hospital to the MAC. The effective date of enrollment is the date when the attestation was accepted by the MAC. An on-site survey is not required for approval.

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