Would CMS Allow Concierge Emergency Departments?

I recently wrote about Concierge Emergency Departments. There are challenges to such a model.

Scalpel, who blogged about free-standing EDs in Texas last year, commented:

"The concept won't work unless Medicare and Medicaid are excluded because you can't balance bill."

Can we separate care from amenities? We can't balance bill on care, but can we charge for amenities? Patients visiting the ED can purchase food from the cafeteria. They can also purchase bottled water from a vending machine in our lobby. I don't believe this violates any CMS billing standards. Even though, some patients have coins for the vending machine and others do not. Do regulations prohibit charging for a private fancy chair versus a standard waiting room chair?

Those waiting in a non-private area need to receive the same level of care. Comfort scores and pain scores could be difficult to separate. How would we audit and defend the differences?

Peter from Medical Pistache commented:

"An individual may need to visit the ER once every 5 years perhaps. Few would be willing to pay a yearly subscription for services unlikely to be needed every year."

A subscription model is one model. Segmentation of services by price and per visit would provide more service options. You can get first class, business, or coach seats on a flight. Different prices and levels of service, yet all include a chair in the sky that transports you from point A to point B.

Emergency departments generate 119.2 million visits per year. That is 227 visits per minute. An extra $1 here, or $10, or $100 there could add up to significant revenue for hospitals. Service profit could be applied to help pay for the care of all patients.

Thanks to KevinMD and GruntDoc (two of my daily reads) for their referrals.

Comments

[Peter]

Consistency of care is indeed an issue. As you have mentioned, when an individual notices another individual who is receiving additional benefits while being taken care of (private plasma TV results waiting room), there will be unnecessary animosity and a tendency by the "disadvantaged" patient towards seeking justice.

"How come this patient gets this benefit and I don't? I don't have money to pay for the amenities, but I want them! This is unfair!"

(Such is the echo of the entitlement mentality, pervasive among Americans.)

The best way to have consistency of care within the same institution and to avoid the appearance of favoring some patients over others, is to have a universal price/benefit structure. I do not think the public would approve of the distinction of "haves" and "have-nots" within the same ED; however, if all the "haves" have their own ED and all the "have-nots" have their own ED, there would be little conflict over disparities. Some may decry the sociological travesty of this configuration in much the same way they decry the disparity of amenities of suburban and inner-city hospitals. Even so, the vast majority would have little problem with this setup because the distinctions of amenities have been made to the patient before even entering the ED.

"If you are willing to pay a little extra, you should go to the XYZ emergency room, it's the nicest place in town! You can even watch the football game in HD while you're waiting."

versus

"Yeah, you don't have the extra money, so you should go to ZYX emergency room. You will get great care, but you will have to miss out on the football game. They don't even have a TV in the waiting room."