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ASCA’s Latest Podcast Episode Discusses Hospitals Without Walls Program

ASCA CEO and Government Affairs director talk about its conception and possible future

BY SAHELY MUKERJI | SEPTEMBER 2021

In the newest episode of ASCA’s Advancing Surgical Care Podcast, “A Closer Look at Hospitals Without Walls,” Kara Newbury, ASCA’s regulatory counsel and director of Government Affairs, and Bill Prentice, ASCA’s chief executive officer, discuss the program’s first year, evaluate what worked and what did not and consider the future and long-term effects of this initiative.

The Centers for Medicare & Medicaid Services (CMS) developed the Hospitals Without Walls (HWW) program back in March 2020, during the first months of the COVID-19 pandemic, to give nonhospital healthcare facilities, including ASCs, a hospital status. The program allowed the participants to provide expanded services to Medicare beneficiaries during the public health emergency.

The HWW program permits eligible ASCs to either partner with a hospital or apply for hospital status on a standalone basis. The intent of the program was to enable alternative sites of care, as long as they met certain conditions, to non-COVID-related patients, freeing up hospital capacity to treat the surging number of COVID-19 hospitalizations. ASCA was an early advocate and supporter of the program, largely because it recognized that ASCs were set up to provide the same level of care as hospital outpatient departments (HOPD).

CMS announced that it would reimburse ASCs at the hospital rate for care provided to patients who otherwise would have been treated in the hospital setting. ASCs could work with their local hospital to take on additional cases or enroll as a hospital themselves. “This new reimbursement policy should not be misconstrued as a way to simply obtain higher reimbursement for an ASC’s regular mix of patients,” Prentice said in the podcast episode.

Newbury cautioned that the program was initiated under a different administration and there might be changes to the program with this new administration. “Anyone who's thinking about doing the program and participating solely to obtain higher reimbursement … there might be a review process and an audit of the facilities that participated, ensuring that they did participate and meet the requirements of the program.”

Participation in the program has been modest, largely because hospitals were not overwhelmed with COVID patients in many parts of the country. As of September 8, 2021, 137 ASCs have enrolled as a hospital. “There is a chance that CMS would wind down this program in the next several months,” Newbury said. “Partially due to lack of participation, and from [CMS’] perception, potentially a lack of nationwide need at this point.”

Prentice shared that in a recent call with the deputy administrator of CMS, ASCA suggested a future meeting to go through the lessons learned from this pandemic and figure out a plan to keep a program like HWW on the shelf for use later in this pandemic, the next pandemic or another emergency that might happen on a more localized level.

Listen to the podcast episode.