The Centers for Medicare and Medicaid Services recently released a memo clarifying guidance under Appendix A of the State Operations Manual (SOM). This guidance is meant to shed light on the definition of a hospital under the Social Security Act.
With the rise of “microhospitals,” small facilities that operate like acute care hospitals with a low number of inpatient beds, there has been some confusion regarding the certification process for such facilities. A variety of other facility models have run into the same issues, as care providers attempt new innovations in care and locations that may stray from the traditional idea of a hospital facility.
The CMS memo clarifies that the federal Medicare definition of a hospital under the Social Security Act may not always mesh perfectly with state requirements for the same certification. That is, “a facility may have a license from a state to operate as a hospital,” but “that facility may still not meet the Medicare definition of a hospital.” Hospitals approved, certified, and licensed by state or local authorities are still required to fit the Medicare criteria, including Conditions for Coverage (CfCs), Conditions of Participations (CoPs), and observations by the CMS Regional Office in order to be approved to accept Medicare patients. The details of these observations are described in the memo, linked above.
To read more about microhospitals and their growing role in the care delivery system, click here.