Federal and state agencies have been issuing waivers for various regulatory requirements in order to give healthcare providers more flexibility to provide essential care during the COVID-19 emergency. Intermountain’s Legal and Compliance departments are analyzing these blanket and specific waivers announced by the Centers for Medicare & Medicaid (CMS) and other regulatory bodies. We are working with operations and clinical leaders to determine which waivers are helpful in our response to the COVID-19 pandemic, such as those that temporarily adjust requirements for areas including telehealth, medical records, and professional licenses. We’re also working with state and federal officials to implement appropriately across our system.
We understand the urgency to make these adjustments. However, before we can change processes based on a waiver, there must be proper internal vetting and approval, and documentation that we’ve made an exception to any Intermountain policy, procedure, or guideline (PPG). This work is being coordinated by Meghan Flaherty, Diane Rindlisbacher, and Dana Abufarha. These steps are:
- Compliance must review all waivers; legal will review when necessary.
- An system-designated operational leader is responsible for developing any new processes based on the waiver.
- Incident Command oversees the process.
- We will document all new processes on a new website, which just launched and will continue to be populated.
If the regulatory requirements you normally work under are a barrier to providing care during the COVID-19 pandemic, please share the barriers by emailing LegalComplianceCOVID19@imail.org. This channel will connect you to the right people (in Legal, Compliance, or Operations) who will help you respond. Leaders may submit barriers on behalf of their teams. Even if you think a waiver has already been granted related to the challenge, share your challenges so we can ensure are supported. If you do not find information about a waiver you would like to use, please reach out to the team.
In your message to LegalComplianceCOVID19@imail.org, include:
- The requirement that is a barrier to care.
- A paragraph about why this requirement is a barrier.
- Specifics about the barrier (see examples below):
- Timing challenges
- Documentation requirements
- Billing difficulties
- Reporting challenges
Thank you for your dedication to serving our patients and communities.
Resources
- Contact: LegalComplianceCOVID19@imail.org
- CMS Waiver information: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf