Intermountain’s Legal and Compliance teams are analyzing each waiver and working with operations and clinical leaders to determine whether it should be implemented. Some waivers may have specific requirements that must be met or actions that must be taken to qualify for the flexibility.
If a waiver is eligible for implementation at an Intermountain location, specific information is posted on the COVID-related Waivers page on Intermountain.net. Compliance follows up with implementation owners regularly to provide support to operations.
We must document the implementation of each waiver. This will allow Intermountain to show regulators a thoughtful application of each waiver, as well as provide a guide when the public health emergency ends and waivers expire.
Waivers will expire after COVID-19. Each COVID-19-related regulatory waiver is inherently tied to the current public health emergency and is limited to actions taken due to the COVID-19 response. Intermountain must unwind implementation after the pandemic ends.
Here are two helpful examples of how waivers may have specific limitations or requirements that must be met:
- Privacy Waiver: One waiver relaxed a standard HIPAA requirement for COVID-19-only community screening sites, but for this one requirement and not for any other purposes. For patients at COVID-19 community-based testing sites, Intermountain isn’t required to post or provide copies of the Notice of Privacy Practices (NPP). It’s a best practice but not required. Sites offering any other service beyond COVID-19 screening, however, must provide the NPP per standard practice, including for non-COVID-19 drive-through services like other types of lab testing.
- Out of State Licensure: Traditionally, healthcare providers must be licensed in the state where the patient is located. In response to COVID-19, the federal government has created flexibility for the practice of medicine across state lines, including for virtual visits. However, each state has responded to COVID-19 differently, with varying levels of flexibility for providers who aren’t licensed or certified in that state.
If you have questions about waivers, please contact LegalComplianceCOVID19@imail.org.