QualityNet Communications Hub

Important references and responses

Website reference for external inquiries: https://qualitynet.cms.gov/acute-hospital-care-at-home 

Hospital at Home Users Group: https://www.hahusersgroup.org/ 


Template for email to schedule a call with a requesting hospital:

Good afternoon (POC),

Thank you for submitting a waiver request for Acute Hospital Care at Home on behalf of (Hospital).  As part of our review process, our team of physicians and nurses schedule a Zoom call with requesting hospitals.  This allows us to ask clarifying questions, and we typically ask the hospital’s team to walk through a hypothetical patient and each interaction with the hospital system throughout their admission.  This also gives your team a chance to ask any questions to CMS.  Typically, leaders from hospitals in roles like CMO and CNO or equivalent and members from the operations team attend.

If you can send us a few times that work in the next week or so, I’m sure we can make one of them work.  We know that your team members have busy clinical schedules and we can work around them!

Thank you, and please reach out with any questions!


Other details/insights

  1. Currently this waiver will end with the ending of the Public Health Emergency. Website reference: https://www.phe.gov/emergency/news/healthactions/phe/Pages/default.aspx 
  2. Reference to the Governor's Letter indicating DHHS will give notice prior to the end of the PHE: https://ccf.georgetown.edu/wp-content/uploads/2021/01/Public-Health-Emergency-Message-to-Governors.pdf
  3. NOTE: Hospitals that may have been participating prior to the PHE or beyond the PHE May choose to do so under Medicare Advantage or private insurers. This is possible without federal oversight because those services are receiving Medicare payment and therefore not subject to Medicare requirements under their provider agreement. The services are not billed to a hospital CCN. The reference provided is for Hospitals subject to a Medicare provider agreement. There may be state licensure requirements that would preclude these activities, but that would be under the authority of the state and not CMS.


Waiver evaluation: IJ Review

If you have a hospital that has an immediate jeopardy (see the excel files sent in Slack) you can pull the survey that resulted in the citation review the basis for it using this website. http://www.hospitalinspections.org/  Once you review the citation, we can look at it together as a team to determine if it should affect our decision-making re: the waiver.  It's not disqualifying if they have, but we'd want to take a look at what happened and make that part of our evaluation.


Waiver evaluation: Tier 1

  1. Review the request in JIRA, including:
    1. Verify that all of their attestations were “Yes.”
    2. Verify attester is an appropriate C-suite exec – this has been an issue that about half of requests have not done correctly. If everything else is OK, can have them email you from the right person that they have reviewed and attest and append that email to the online ticket as a pdf file. If there are multiple things wrong, easier for them to resubmit – but then we need to ask the ISG team to delete the original ticket.
  2. Verify no IJ in the past 2 years using the Excel files uploaded to the Slack channel
    1. If there is, see above for the exact report for further review
  3. Schedule a call with the POC/hospital team (see template email above) for further discussion and clarification of their workflow (see Tier 2 evaluation below).  For Tier 1 programs that we know about and have been “vetted” by our academic experts or one of the three private firms we worked with (Contessa, Dispatch, Medically Home), we have not been following up with a phone call if the request is properly completed.  Typically we get consensus among the group for direct approval.
  4. Add a comment or several to the bottom of the ticket in JIRA to briefly describe your thought process and that there were no IJ’s, etc.


Waiver evaluation: Tier 2

  1. Review the request in JIRA, including:
    1. Review all sections of the request, taking special note of how the request addresses
      1. Team communication/collaboration
      2. Patient assessment of fitness for the program (including cognitive issues, DME needs and coordination, presence of caregiver, etc)
      3. Oversight of any third party vendors
      4. Workflow on day zero (i.e., how patient gets home and who meets them to set up)
      5. EMR interoperability/documentation
      6. Plans for urgent response/escalations and disaster response
    2. Verify attester is an appropriate C-suite executive – this has been an issue that about half of requests have not done correctly. If everything else is OK, have the POC email you that the right person has reviewed and attest and append that email to the online ticket as a pdf file. If there are multiple things wrong, easier for them to resubmit – but then we need to ask the ISG team to delete the original ticket in JIRA
  2. Verify no IJ in the past 2 years using the Excel files uploaded to the Slack channel
    1. If there is, see above for the exact report for further review
  3. Add a comment to the ticket in JIRA based on your preliminary review, noting any issues related to item 1(a).  Briefly describe your thought process and document whether any IJs.
  4. Schedule a call by emailing the POC/hospital team (see template email above) for further discussion and clarification of their workflow (see Telephone SOP below)
  5. Following the scheduled call, address any concerns initially noted in your original comment and whether or not team will approve or deny or other action.


Telephone/Zoom discussion SOP for evaluation team

  1. Open the call with introductions
  2. Turn over to the hospital team to walk us through "a day in the life of a patient in their hospital-at-home program".  Take special note of: 
    1. Elements of team communication, collaboration
    2. Patient assessment of fitness for the program (including cognitive issues, DME needs and coordination, presence of caregiver, etc)
    3. Oversight of any third party vendors
    4. Workflow on day zero (i.e., how patient gets home and who meets them to set up)
    5. EMR interoperability/documentation
    6. Plans for urgent response/escalations and disaster response
  3. Follow-up on any areas that need clarification, or concerns noted in preliminary review of their waiver request (as described in reviewer's comments in JIRA)
  4. Ask the "2am" question: "If a patient or their caregiver needed to speak with the team at 2am, how do they get in touch with you?"
    1. Be sure there is an immediate access to a live person who can triage/connect with a team member to assess the situation
    2. Assess their response capabilities and confirm their workflow for escalation
  5. Ask the "apocalypse question" if they haven't already addressed: "in a situation where the home setting becomes unsafe, as in a natural disaster (hurricaine, wildfire, etc) or even a blackout, what is your protocol or plan to address the care of the patient?"
  6. Close the call with next steps, including the fact that we will briefly review and follow-up in 24-48 hours with a decision
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