By Lambert Strether of Corrente.
I keep noticing how civilized countries are handling #COVID-19 (Bangkok Post: “Virus covered by universal health care“) in contrast to our own (Politico: “Schumer calls for Medicare to cover coronavirus vaccine that is still in development.” Come on, man. Over-65s only? No coverage for testing? Really?). So I was intrigued when I saw the following tweet from Carlos Mucha, responding to Sarah Kliff:
The acronym for the day is NDMS. Once (if?) the President declares a public health emergency, Uncle Sam is on the hook for out-of-pocket medical costs via the National Disaster Medical System. https://t.co/rVfYOf26FY pic.twitter.com/2PPwerteuQ
— Carlos Mucha (@mucha_carlos) February 29, 2020
(Mucha has a lot of credibility in certain circles, because he was the modern originator of the MMT-adjacent Trillion Dollar Coin concept, legitimized as not cray cray by Politico here, and don’t @ me. Mucha is, in other words, good at combining lateral thinking with complete legality, and this NDMS reimbursement concept sounds like it could solve a lot of our problems mitigating #COVID-19.)
In this post, I’ll only look at the NDMS reimbursement concept, because I suspect that’s what most readers are reallly interested in. I hope at some future point, to take a look at NDMS itself, because it seems to be that rare thing in government these days: An agency with operational capability. (Googling turns up very little Beltway news on NDMS, but a lot of home-town stories about NDMS people who were deployed into emergency situations, upon their homecomings.) My real hope for this post — and this is exactly what happened with the Trillion Dollar Coin, which propagated from the blogs outward — is that that the idea will propagate into the mainstream media, and thence to either the administration, or the campaigns, or both.
To the reimbursement concept. First, a Public Health Emergency has been declared for #COVID-19, so NDMS reimbursesments can kick in. It seems to be hospitals who are reimbursed, not patients, but I assume that’s all to the good. (Pause here to envision some insane liberal scheme to reimburse patients through tax credits, after means-testing them.) From the Department of Health and Human Services (HHS):
As part of the Trump Administration’s government-wide efforts to provide relief to those affected by Hurricane Irma, the U.S. Department of Health and Human Services (HHS) activated a program to help hospitals and medical facilities providing care to people affected by Irma. This is the first time HHS has activated the program in response to a natural disaster since a devastating earthquake hit Haiti in 2010.
The program, called the National Disaster Medical System (NDMS) Definitive Care Reimbursement Program, reimburses medical facilities and hospitals for the definitive medical care costs of patients medically evacuated following disasters. These patients are directed to NDMS-designated hospitals and medical facilities and tracked through Federal Coordinating Centers managed by the Departments of Veterans Affairs and Defense.
And here are the NDMS coverage guidelines in detail. First, eligibility:
A condition of NDMS coverage is that the patient is transported via Federal assets, processed through a FCC, and referred to facilities or practitioners for Definitive Medical Care. The NDMS tracks all patients who are transported via Federal assets and thus, are eligible for coverage under this program.
OK, organize an NDMS #COVID-19 program to provide transport as — follow me closely here — the gateway to NDMS reimbursement as a universal concrete material benefit (probably good for standardizing protocols anyhow): And now the providers:
Only providers who currently participate in either Medicare or Medicaid are eligible for reimbursement. All providers who participate in Medicare will be reimbursed based upon their Medicare rates. Any provider who does not participate in Medicare but does actively participate in Medicaid will be reimbursed based upon their Medicaid rates.
Next, covered services:
Generally, any medically necessary service which is authorized under Medicare Part A, Medicare Part B or a State’s Medicaid program is eligible for reimbursement as long as the NDMS patient sustained one of the following:
- Injuries or illnesses resulting directly from a specified public health emergency; or
- Injuries, illnesses and conditions requiring essential medical services necessary to maintain a reasonable level of health temporarily not available as a result of the public health emergency; or
Injuries or illnesses affecting authorized emergency response and disaster relief personnel responding to the public health emergency.
That would seem to cover not only #COVID-19, but testing for #COVID-19.
The program ends after 30 days; IIRC #COVID-19 runs its course in two weeks.
Finally, the benefit guidelines:
The NDMS Reimbursement Program will pay primary under the following circumstances:
- The patient is uninsured.
- The patient is covered only by Medicaid.
The patient is only covered by other state or local payer of last resort.
For individuals with private coverage (e.g., employment-based coverage), the NDMS Definitive Care Reimbursement Program may make a secondary payment to cover the difference between the full NDMS payment amount and the other payer’s allowance(s). However, NDMS does not cover co-pays, deductibles or coinsurance associated with the patient’s other coverage other coverage(s)— this includes any Medicare or Medicaid co-pays, deductibles or coinsurance.
Too bad about the co-pays and deductibles (and that Medicare and VA aren’t integrated, so we had true single payer.) One could, I imagine, do a little lateral thinking and get thrown off one’s insurance program by not making payments, thereby becoming “uninsured,” but there are probably better solutions to be had. (I’d also welcome comments from readers far more experienced in disentangling benefits programs than I am.)
It remains only to determine who activates the NDMS. From DOD INSTRUCTION 6010.22 NATIONAL DISASTER MEDICAL SYSTEM (NDMS):
In accordance with Section 300hh-11 of Title 42, U.S.C., HHS activates the NDMS or specific capabilities of the NDMS, depending on the situation. The Secretary of HHS activates the appropriate FCCs by notifying the VA and DoD program managers in writing. Activation may be in response to:
(1) A national emergency, domestic disaster, or in support of a homeland security event.
(2) The Secretary of HHS declaring a public health emergency in accordance with Section 300hh-11 of Title 42, U.S.C.
As we know, HHS has already declared #COVID-19 a public health emergency, so President Trump could order HHS to activate NDMS tomorrow.
Of course, the reimbursement procedure outlined is trying to be #MedicareForAll, albeit on an emergency basis for a single disease, so Trump might be considered to be unlikely to activate it. On the other hand, if Trump really wants to own the libs — and what good conservative doesn’t? — this would be a wonderful way to do it; Steve Bannon could be called in to handle the re-branding (“LibertyCare”).
Speculating wildly: It has not escaped our notice that if a Sanders administration wished to implement #MedicareForAll by executive fiat, it would begin by declaring that the 55,000 deaths per year caused by our current, for-profit system constitute a public health emergency. And don’t they?
Comments welcome from readers really expert in navigating these programs!
 The best definition I can find: “Definitive care is usually considered the domain of the hospital and of larger facilities and implies the resolution of the condition needing treatment.” Subject to correction with those who have experienced it, “definitive care” does not seem designed to deny care.