As part of the response to COVID-19, CMS has issued a number of blanket waivers creating a “Hospital Without Walls” program. The program allows hospitals to bill Medicare for services they provide in other health care locations (such as Ambulatory Surgery Centers or non-traditional locations - such as hotels), and may allow limited restoration of certain types of care. Join Polsinelli attorneys as they cover the basics of the Hospital Without Walls program and related state and federal legal issues.

Agenda

• Description of CMS’s blanket waivers creating the Hospitals Without Walls programs

• Discussion of state and local hospital licensing considerations for using non-traditional space

• Analysis of special considerations for categories of health care providers, such as ambulatory surgery centers

• Assessment of related issues including use of telehealth, real estate contracting considerations, and economic impact