Supporting Healthcare Services During and After Tropical Storm Debby: Hypothetical State Waivers from CMS

In response to the devastation wrought by Hurricane Debby, which has since downgraded to Tropical Storm Debby, the Centers for Medicare & Medicaid Services (CMS) has swiftly mobilized to offer additional resources and flexibilities to support the states of Florida, Georgia, and South Carolina.

With President Biden’s emergency declarations and HHS Secretary Xavier Becerra’s determinations of a Public Health Emergency (PHE), CMS is focused on ensuring that healthcare providers in these storm-ravaged regions can continue to deliver critical services to affected populations. Among the key measures being rolled out are state waivers designed to mitigate the disruptions caused by the storm and to facilitate the continued operation of healthcare services.

Temporary Suspension of Certain Medicare, Medicaid, and CHIP Requirements

One of the most immediate and impactful waivers that CMS could implement involves the temporary suspension of certain Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) requirements. For example, CMS might grant waivers that allow healthcare providers to offer services in alternative settings, such as temporary shelters, community centers, or even mobile units, without the need for prior approval or a formal site certification. This would enable medical professionals to deliver necessary care to individuals who have been displaced by the storm and may not be able to access their usual healthcare facilities.

In addition, CMS could waive certain documentation requirements, such as prior authorizations and in-person visit mandates, for the duration of the emergency. This would allow providers to deliver care more efficiently, without the administrative burden that can delay treatment. For instance, if a patient requires urgent medication refills but cannot visit their regular doctor due to storm-related disruptions, a waiver might allow a pharmacist or an out-of-network provider to refill the prescription without the usual procedural requirements.

Flexibility in Staffing and Licensure

Another critical area where CMS could offer support is in the flexibility of staffing and licensure requirements. The storm may have resulted in healthcare workforce shortages due to evacuations, damage to facilities, or transportation challenges. In response, CMS might temporarily waive the requirement for healthcare providers to be licensed in the state where they are providing services, as long as they hold a valid license in another state. This would enable healthcare workers from neighboring states or even unaffected areas within the same state to be quickly deployed to regions in need, thereby bolstering the local healthcare response.

Adjustments to Reimbursement and Reporting Requirements

CMS could also introduce waivers that modify reimbursement and reporting requirements to ease the financial and operational burdens on healthcare providers in the impacted regions. For example, hospitals that experience an influx of patients due to the storm might receive enhanced reimbursement rates to cover the additional costs associated with emergency care, such as overtime pay for staff or the use of temporary facilities. CMS might also provide accelerated payments to providers facing cash flow challenges due to the disruption of routine services.

Conclusion

By suspending certain regulatory requirements, adjusting reimbursement and reporting obligations, and expanding telehealth services, these waivers would play a crucial role in ensuring that residents of Florida, Georgia, and South Carolina continue to have access to the essential medical services they need as they recover from the storm.