By Bruce Chernof, MD, President and CEO, The SCAN Foundation
Unprecedented times call for unprecedented action, and the Centers for Medicare & Medicaid Services (CMS) has been quick to respond. In the last few weeks, CMS has issued an array of waivers and rules creating new flexibilities that allow health systems to respond to the growing challenges brought forth by COVID-19. These new flexibilities allow health systems to build off current capacities tested in recent years, as well as implement strategies that have never been done before.
People with complex care needs are at the most risk during this pandemic, and federal policies are evolving daily to respond to the current environment. The Better Care Playbook now offers a COVID-19 resource center that compiles federal policy information impacting the care for individuals with complex care needs. Here are highlights of some flexibilities that could positively influence both medical and non-medical services for people with complex care needs.
- Telehealth was slowly being tested and implemented with a restricted set of providers, but now is being used in new ways with CMS funding telehealth for 80 additional services.
- Beneficiaries may receive telehealth visits in any health care facility and in their home.
- Medicare is now funding phone-based therapy for mental health services, which wasn’t the case a month ago.
- Home health providers can use telecommunications to monitor individuals remotely in ways that align with their plan of care.
- Home- and community-based services can assess and deliver services in new ways to support social distancing and reduce risk of exposure for people with complex care needs.
- Nurse practitioners, clinical nurse specialists, and physician assistants can now order home health. This regulatory change is intended to remain in place.
- Home health providers can assess needs and provide support remotely. This will require processes for determining who in fact needs a home visit, and what types of visits are considered essential.
- Physicians can order home-based services (e.g., home-delivered meals, preventive services and caregiver support services) under the relaxed definition of “home-bound” that now includes individuals staying home due to COVID-19.
- Medicaid Waivers (i.e., 1135, Appendix K of 1915c) as well as a blanket waiver have been approved by CMS to give states the following emergency flexibilities and more.
- States can enroll out-of-state or new providers more quickly to be responsive to workforce demands.
- Prior authorization requirements are temporarily suspended to reduce administrative burdens and respond to needs more quickly.
- Some states are allowing care coordination to be provided remotely, and increasing the number of monthly billable hours for care coordination.
Considerations for Health Systems – Now and for the Future
Health systems that have focused on elements of system transformation such as care coordination, value-based purchasing, integrated care, and social determinants in recent years are better poised to engage these flexibilities and serve people with complex care needs during this crisis. While exercising new flexibilities in response to COVID-19, health systems must keep the person at the forefront by implementing principles of person-centered care.
Building off of the flexibilities afforded by CMS, here are five considerations for health systems today.
- As flexibilities are implemented to respond to short-term needs, consider how various flexibilities can be used to improve services and supports in the long-term when we are on the other side of this pandemic.
- Identify what resources are currently underutilized, and communicate what additional flexibilities are needed to use these resources more creatively to meet the needs of people with complex care needs.
- Responding to COVID-19 requires the use of medical and non-medical services as is evident in CMS’ policy response. Use the opportunity for rapid learning and build long-term solutions.
- Act deliberately, identifying where caution should be required in responding to the new flexibilities, and act in the best interest of individuals with complex care needs.
- Create processes for evaluating whether the right changes were made, and whether they should remain in place after the crisis is over.
While unprecedented times call for unprecedented measures, they inevitably create space for innovation and learning. As health systems focus on short-term crisis interventions, what we learn today and the capacities built will shape the future of care for people with complex care needs. How might current crisis solutions be leveraged for future system transformation? Health systems must engage nuanced strategies that address short-term needs with a long-term view for the future. This involves focusing not only on administration of services in a crisis response, but also on how to leverage today’s crisis solutions to strengthen the system of care and better serve individuals on the outset.