The COVID-19 pandemic has changed healthcare. Most attention has been paid to shifts in telemedicine and remote work, but other changes are emerging. One of the biggest is the concept of the “hospital at home”.
For hospitals, this program represents a shift that will likely change the concept of the hospital and impact hospital billing for years to come. Here’s what you need to know about the hospital-at-home model today.
As hospitals struggled with capacity issues during a surge of the COVID-19 virus, CMS allowed some providers to participate in a new program. The “Acute Hospital Care at Home” programs (also known as “hospital-at-home”) allowed hospitals to ease the capacity burden by delivering acute care outside of their usual physical restrictions. It allowed patients who required acute inpatient admission or daily rounding by a physician and medical team another option — receiving hospital-level care at home.
These patients were subject to a strict screening process to examine medical and non-medical factors. These factors included physical barriers, screening for domestic violence concerns, in-person evaluations, and a check for working utilities.
But the concept isn’t completely new. Similar models came about in the 90s with early adopters like Johns Hopkins University, a successful pioneer of its own version. Hospitals Without Walls models were approved in March 2020, opening up regulatory flexibilities that gave hospitals the ability to deliver acute care services in locations outside the hospital premises.
The pressures of a pandemic simply accelerated adoption. According to CMS Administrator Seema Verma, “We’re at a new level of crisis response with COVID-19 and CMS is leveraging the latest innovations and technology to help healthcare systems that are facing significant challenges to increase their capacity to make sure patients get the care they need.”
The model involves most of the same elements you’d find in inpatient settings. RNs evaluate qualified patients, with two in-person visits happening daily from either RNs or mobile integrated health paramedics. The program was premiered across six health systems, including Mount Sinai Health System in NYC and Huntsman Cancer Institute in Utah. Research has supported the effectiveness of the program, with results including fewer readmissions, reduced mortality, and cost savings.
This model has raised many questions and concerns around hospital billing. Thankfully, the interim final rule (IFR) published on April 30, 2020, provided increased flexibility in providing care, but also receiving Medicare outpatient reimbursement.
Essentially, CMS decided that the patient home can be treated as a temporary expansion location, and that these locations can be treated as provider-based departments of the hospital. This treatment was allowed to stand as long as care wasn’t inconsistent with a state’s emergency preparedness or pandemic plan.
CMS has not required that hospitals enroll hospital-at-home locations as hospital locations. Additionally, no updates are required to a hospital’s 855A/PECOS enrollment record. At the same time, if the original location of service that’s been moved to the patient’s home was an “excepted” location for Medicare Outpatient Prospective Payment System (OPPS) site-neutral payment rules, then the hospital can receive the full OPPS rate for relocated services. (This is true if additional materials are submitted to CMS).
According to The National Law Review, under this model, hospitals can bill for and receive payment for hospital facility fees that are associated with certain “hospital therapeutic services” as covered under 42 CR 410.27 . This applies when services are furnished by hospital clinical staff and include outpatient therapy, counseling, and educational services. At the same time, these services do not include a separate professional services fee. Hospitals can bill the facility fee for home services since the patient home is being treated as a location within a hospital.
CMS is also permitting hospitals to bill a facility fee when certain services are provided remotely to a patient in their home by hospital staff. These are services that the agency has determined don’t require in-person performance and that they would otherwise cover in a hospital setting if the patient and staff were in different locations.
Hospitals should be aware that the agency has modified the application process. Excepted locations moved to a patient home or other temporary location on or after March 1 2020 for addressing the COVID-19 emergency have to submit documentation to their correct CMS Regional Office. The submission should include:
Hospitals looking for more information and up-to-date details as hospital billing changes with the pandemic should refer to the CMS FAQ and general CMS announcements .
 E. J. Cook, E. M. Palmer, L. S. Mazur and M. McDermott, “Hospital At Home – CMS Expands Payments To Hospitals For Care Provided In Patient Homes,” The National Law Review, 12 May 2020. Available: https://www.natlawreview.com/article/hospital-home-cms-expands-payments-to-hospitals-care-provided-patient-homes.
 CMS, “Acute Hospital Care At Home Program Frequently Asked Questions,”. Available: https://www.cms.gov/files/document/covid-acute-hospital-care-home-faqs.pdf. [Accessed 18 March 2021].