On April 3, 2020, CMS published a memo (QSO-20-24-ASC) outlining the steps for processing attestations and certification kits for certain existing Medicare certified ASCs that choose to temporarily enroll as a hospital during the COVID-19 public health emergency. CMS emergency waiver authority created additional flexibilities to allow enrolled ASCs to temporarily enroll as hospitals and to provide hospital services to help address the urgent need to increase hospital capacity. Please note the following:
- Only ASCs located in areas/states where the ASCs are working in conjunction with their State and local Health Departments are eligible to participate;
- The ASC would have to comply with all applicable hospital Conditions of Participation, as these have not been waived in totality (e.g., must have 24-hour nursing services, pharmacy services, etc.);
- Individual State Survey Agencies will determine if a modified survey will be required, in addition to the signed facility attestation; and
- The waiver does not allow the provider to be enrolled both as an ASC and hospital at the same time. (The memo does indicate the process for resuming ASC function at the conclusion of the public health emergency)
The memo (linked above) outlines the specific steps that must be followed in order to utilize the new flexibility, including the required attestation form that must be completed. The QUAD A team will be available to assist you with questions you may have and in navigating the temporary enrollment process. Please keep in mind, for ASCs that do not qualify for this flexibility can still provide hospital services through contract/arrangements with area hospitals in need of such services.
