CMS Guidance on Government Billing for Alternate Care Sites

May 27, 2020

In response to the COVID-19 pandemic, state and local governments, hospitals, and others have developed alternate care sites (ACS) to expand capacity and provide needed care to patients. An ACS is a broad term for any building or structure that is temporarily converted or newly erected for healthcare use. The Federal Healthcare Resiliency Task Force issued a toolkit to help state and local governments develop an ACS.

A new Fact Sheet from the Centers for Medicare & Medicaid Services (CMS) provides information to state and local governments that are considering developing an ACS on how to seek payments through CMS programs – Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP) – for acute inpatient and outpatient care furnished at an ACS.

The easiest path to obtaining payments through CMS programs for covered health care services furnished at an ACS is for an already-enrolled hospital or health system to treat the ACS as a temporary expansion of its existing “brick-and-mortar” location. State and local governments that desire to establish (i.e., develop or build) a hospital ACS, and be paid by CMS for furnishing covered hospital inpatient and outpatient services to enrolled beneficiaries, have three options: (i) hand over operation and billing for care delivered in the ACS to a hospital or health system that is already enrolled in a CMS program; (ii) enroll the ACS as a new hospital in CMS programs; or (iii) if options (i) and (ii) are not available, CMS could not make facility payments, but qualified and enrolled physicians or other non-physician practitioners could bill for covered (professional) services that they furnish at the ACS.

Additional information regarding new hospital enrollment and the flexibilities that existing hospitals and other providers have to expand capacity at ACSs during the COVID-19 pandemic can be read in the fact sheet.