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How ASCs can temporarily convert to hospitals under Medicare — 7 things to know

An April 3 memo from CMS outlines the process for temporarily enrolling a Medicare-certified ASC as a hospital during the COVID-19 public health emergency.

Seven key takeaways from The National Law Review:

1. To begin enrolling as a hospital, any Medicare-certified ASC must first notify and submit a signed attestation statement to the Medicare administrative contractor serving its jurisdiction. The MAC will review and send the attestation to an applicable CMS regional office, which will evaluate the ASC's compliance with state survey standards.

2. The regional office will deny a request for temporary hospital enrollment if the ASC has been cited by a state survey agency within the last year for any immediate jeopardy deficiency, meaning a deficiency that caused or was likely to cause serious injury, harm, impairment or death of a patient.

3. ASCs cannot simultaneously enroll in Medicare as an ASC and as a hospital; ASC billing privileges will be deactivated while a center is enrolled and reimbursed as a hospital. ASCs do not need to undergo an on-site survey for temporary hospital enrollment, but the CMS regional office may authorize a state survey at a later date.

4. Attestation statements for qualifying ASCs will be approved by the regional office within two days of receipt. Each approved ASC will receive a hospital CMS certification number. The regional office will then notify the MAC that the ASC is permitted to enroll as a hospital, and enrollment will take effect on the date of subsequent MAC approval.

5. At the end of the public health emergency, ASCs will have their hospital CMS certification numbers terminated, their hospital billing privileges deactivated, and their ASC billing privileges reinstated. However, at any time, centers can revert back to ASC status by notifying the MAC.

Any ASC that wants to continue participating in Medicare as a hospital after the public health emergency will need to submit form CMS-855A and undergo related surveying.

6. To enroll in Medicare as a hospital, ASCs must meet the hospital conditions of participation for nursing, pharmaceutical, infection control and respiratory services, as well as any other conditions not waived under Section 1136 waivers. Although Medicare will reimburse ASCs that satisfy the appropriate conditions, it's unclear whether state Medicaid programs and commercial payers will reimburse converted ASCs at hospital rates.

7. CMS issued a nationwide Stark Law waiver permitting physician-owners to refer patients to converted ASCs, so long as the arrangement is made for COVID-19-related purposes. However, physician-owners should consider federal and state fraud and abuse laws such as the Anti-Kickback Statute, for which the Office of Inspector General hasn't yet issued similar waivers.

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