Liver Transplants in Non-approved Centers During the Emergency in Houston

CMS NCA document | source_status=Closed | review_type=New | public_comment_open=False | document_id=CAG-00120N

We believe that the situation in Houston is a catastrophe that warrants special treatment and unique coverage criteria. The situation of a large metropolitan area having three transplant centers which have shut down simultaneously is unique and creates a significant major hardship on beneficiaries. We believe that the health and safety concerns of beneficiaries, who are in situations where forstalling transplantation until the hospital operations are restored may result in death, outweighs the requirement that the facility meet all of the routine Medicare standards. Given the nature of the emergency, the temporary nature of the situation, and the gravity of the effect of postponing the transplant, we believe it is appropriate to cover the transplants at the affiliated hospitals during the period that Memorial Hermann Hospital is closed. Thus, this decision memorandum constitutes a national coverage decision that will permit coverage of liver transplants performed by the team from Memorial Hermann Hospital when performed at Memorial Hermann-Memorial City Hospital, Memorial Hermann Southwest Hospital, and Memorial Hermann Southeast Hospital during the period for which Memorial Hermann Hospital is closed or for 6 months, which ever comes first. Medicare coverage policy in section 35-82 of the Coverage Issues Manual provides for coverage of pancreas transplantation under certain circumstances. We do not restrict pancreas transplantation to approved facilities, but rather will currently cover them in any Medicare participating facility. Thus, no change in the Medicare NCD for pancreas transplantation is necessary in order for pancreas transplantation to occur in the affiliated centers. We are likewise publishing a final rule for kidney transplantation similar to this liver decision.