CMS issued guidance on March 9, 2020, that allows hospitals to set up alternative screening sites on campus and at off-campus, hospital-controlled sites. The guidance provides the following options:

1. Alternative Screening Sites On-Campus – The guidance states that the medical screening exam (MSE) that hospitals are required to provide to every patient that presents to the emergency department (ED) is not required to take place in the ED; hospitals may set up alternative sites on campus to perform the MSEs, including in other buildings on the campus or in tents in a parking lot. Individuals that present to the hospital’s ED may be redirected to an alternative screening site after the individual is logged in (the process of logging in an individual can take place outside the entrance to the ED). The personnel conducting the MSEs at these alternative screening sites must be qualified—physicians, NPs, PAs or RNs trained to perform MSEs. If an individual is found to have an emergency medical condition during the MSE at the alternative screening site, the hospital must provide stabilizing treatment (or appropriate transfer).
2. Influenza-Like Illness Screening at Off-Campus, Hospital Controlled Sites – The guidance also allows for screening at off-campus, hospital-controlled sites for influenza-like illness (ILI). However, individuals that present to the ED cannot be directed to the off-campus screening site. Additionally, hospitals can hold the off-campus screening site out as a screening center for influenza-like illness only—the hospital cannot hold the site out to the public as capable of caring for emergency medical conditions. If an individual presenting for a screening requires additional medical attention on an emergent basis, the hospital is required to arrange for an appropriate referral/transfer. It’s not entirely clear what CMS means by “hospital-controlled,” but presumably a hospital-owned facility such as a clinic or other building would qualify.

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