PINEDALE – Last Wednesday’s contentious meeting between the Sublette County Board of Commissioners and local citizens to discuss the engineering assessment for the construction of a critical access hospital facility in Sublette County was touched on early in the meeting.
But soon thereafter, commissioner Dr. David Burnett gave a presentation on a separate potential option he says could be a solution for health care for in the county.
His potential option was to bring in a freestanding emergency center (FEC), which would provide 24-hour care for life-threatening emergencies.
“It would allow a provision to have 24-hour emergency care,” Burnett said on Thursday. “It would allow them to keep an emergency center open and reimbursed.”
The definition for a FEC in Wyoming was outlined in Senate File 57, which came into effect on July 1, 2016.
“This bill allows for freestanding emergency centers to be operated by a hospital district or a rural health care district,” Burnett said to the audience. “Both would allow for an emergency center physically separate from the hospital.”
He went on to state that the purpose of FECs is to allow rural areas or smaller areas that could have an agreement with a hospital to set up and emergency department.
“This does allow a RHCD to do it independently, which is what’s referred to as a standalone facility, or collaboratively with another hospital … 24/7 for life-threatening emergencies.”
Advantages of a FEC, Burnett told the audience, include no construction cost involved, no license required for operation prior to June 30, 2019, and insurance reimbursement from Centers for Medicare and Medicaid Services (CMS). In addition, he said it allows for local providers to focus on same-day appointments and comprehensive medical care from 8 a.m. to 5 p.m., Monday through Friday, with no on-call obligation, reimbursement for ambulance services from EMS and third-party payers and also would reduce SCRHCD operation costs and losses.
He went on to add that it would satisfy the commissioner’s request for “no harm to the Sublette Center,” would enhance the ability to keep both clinics operational, would allow for 24-hour observation periods and would be an enhancement to the community to provide 24-hour urgent care services.
According to Wyoming Hospital Association vice president Neil Hilton, he isn’t yet sure how viable an FEC would work in Sublette County, as not a single FEC has been set up in Wyoming to this date.
“To me, it seems like an in between,” Hilton said. “It would enhance things to a degree, but in the context with a relationship with another hospital. Is it viable or not? Who knows? None of this is grounded in any type of guarantee.”
He says no guarantee rests with a CAH either, as it boils down to what the community needs and is willing to support.
With the bill passed just last year and the fact that no FECs have been constructed in Wyoming to this date, information on how it would function and be reimbursed is still being worked through at the state level.
“It’s all kind of speculative,” Hilton said. “There’s not one in Wyoming and there’s not really a model of history. The viability would reside within the framework and structure of another hospital and what the financial and operational responsibilities would be.”
The one big positive is that the RHCD has governance structure that would be seen in a hospital district; however, the one thing they don’t have is the licensure in place to receive reimbursements at this point.
“They have a rural hospital district; they just don’t have a hospital license,” he said. “They got part, but not all, of it. The Freestanding Emergency license would have to be attached to (a hospital).”
According to Laura Hudspeth, the administrator of Health Care Licensing and Survey with the Wyoming Department of Health, she is currently exploring with CMS to see if there is a way that health care districts can receive reimbursement.
The one way she believes this could be possible is if the RHCD went the route of provider-based, in conjunction with a hospital or CAH.
“It could be an option,” she said. “We’re exploring it and waiting for a response. It’s very complicated with all the different rules that apply.”
The bill states that on and before June 30, 2019, freestanding emergency centers operated by a hospital district or rural health care district shall not require licensure under this act, provided a hospital transfer agreement is in place. On and after July 1, 2019, freestanding emergency center operated by a hospital district or rural health care district shall comply with all licensure requirements of this act.
“In order to get Medicaid and Medicare like a nursing home or hospital, you must be a provider-based freestanding emergency center,” she said. “If the freestanding emergency center is ‘licensed only,’ it is not a Medicare/Medicaid-certified facility.”
At last week’s meeting, Burnett said he spoke to Hilton and Hudspeth, along with Rep. Eric Barlow out of Gillette, and Wyoming Hospital Association President Eric Boley, and based on those conversations, he felt the FEC idea for Sublette County was “both pursuable and viable.”