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How OSF Healthcare navigates hospital at home during shutdown

The health system's hospital-at-home program is in limbo after the CMS waiver expired, with OSF having discharged all patients and redistributed staff amid the uncertainty.

On Oct. 1, 2025, hospital-at-home providers awoke to a new reality. The Acute Hospital Care at Home waiver, which had enabled the widespread adoption of the hospital-at-home model, had expired, ending Medicare and some Medicaid reimbursement for acute-level hospital care in patients' homes.

As a result of the expiration, more than 400 healthcare facilities with approved waivers were required to discharge or return all hospital-at-home patients to brick-and-mortar facilities by Sept. 30, 2025.

OSF Healthcare was one such health system. Spanning 17 hospitals across Illinois and Michigan, the health system had plans in place to meet the above requirements. However, Brandi Clark, vice president of digital care for OSF OnCall, shared that the health system is bracing for high volumes and increased costs amid the government shutdown and beyond.

Complying with the waiver expiration

The hospital-at-home model emerged in the early 2000s but gained widespread use only during the COVID-19 public health emergency (PHE). In November 2020, CMS launched the Acute Hospital Care at Home (ACHAH) program, which waived certain Medicare Hospital Conditions of Participation for approved facilities, enabling the delivery of acute-level care in patients' homes.

Like most hospital-at-home programs, the OSF OnCall Digital Hospital uses virtual care technologies, including synchronous telehealth and remote patient monitoring (RPM). These tools enable 24/7 access to virtual care teams and continuous monitoring of vital signs. In addition to virtual visits and RPM, patients in OSF OnCall Digital Hospital also have in-person visits with their care team.

The hospital-at-home model has been associated with positive patient experiences and high-quality outcomes, with a 2024 CMS study indicating that the AHCAH initiative was linked to lower mortality rates compared to its brick-and-mortar counterparts.

Though the AHCAH initiative has proved popular and effective, it has been on shaky ground for years. The waiver has been extended in short-term bursts since the end of the PHE in May 2023. Thus, OSF Healthcare has had an alternative plan in place for some time.

"We've been in a situation where we've faced the potential of a shutdown several times over the last couple of years," Clark said. "So we've sort of had this plan on paper for a long time and have had to pull it out and revisit it every time we would be approaching the deadline."

As the most recent deadline, Sept. 30, 2025, loomed, the health system decided to take a proactive approach. Clark shared that the health system's goal was to discharge all patients in the hospital-at-home program by the deadline.

"We did have a contingency plan if we had any patients that were still in the program by the end of the day on September 30th -- we would have transitioned them back to the brick-and-mortar hospital -- but we were able to discharge our last patient before the end of regular business hours on September 30th," she said.

Impact on hospital operations

Although the health system was able to discharge all hospital-at-home patients by the Sept. 30 deadline, it is still navigating an uncertain landscape. Clark believes the waiver will be reinstated when the government reopens, but it is unclear when this will happen and for how long the waiver will be extended.

This has resulted in considerable stress for hospital-at-home providers. For instance, OSF is expecting increases in patient volumes as the respiratory illness season begins.

"As long as the shutdown continues, we will not have the ability to admit patients into the [hospital-at-home] program, thereby relieving some of the capacity constraints in our largest destination hospital that is always at capacity," Clark said.

Additionally, the health system has had to redistribute its hospital-at-home program staff. Clark shared that OSF is retaining all employees in that department. Those employees are still part of the OSF OnCall division, providing care in other areas and cross-training with other departments. 

For instance, hospitalist physicians supporting the hospital-at-home program are also supporting the health system's telehospitalist program, so they are continuing to provide care virtually to many of OSF's smaller hospitals, Clark said.

However, this is resulting in increased costs for the health system.

"At times, we are maybe staffing with an additional person in order to ensure that we can keep those individuals working and retain them so that when the [hospital-at-home] program reopens, we actually are able to do that seamlessly," Clark said.

The health system is also maintaining its contract with its third-party technology vendor, which supports the technical aspects of the hospital-at-home program.

Navigating the uncertainty

OSF Healthcare is participating in various advocacy efforts. At the federal level, its government relations team is engaged in efforts to highlight the value of the ACHAH waiver.

Additionally, the health system is part of an Illinois-based group of hospital-at-home programs. Clark noted that the group, which meets monthly, has provided the state with information on the importance of this model and the need to cover it.

"The great news is there's no real active opposition to hospital at home," Clark said. "So the advocacy is more around ensuring that we aren't forgotten or lost in the minutiae of how our government operates."

Not only is OSF Healthcare engaging in advocacy, but the health system is also exploring other opportunities to utilize its hospital-at-home infrastructure to care for patients in their homes outside of the waiver. One example Clark shared is using the infrastructure for post-surgical patients who require short hospital stays following their procedure. The hospital-at-home infrastructure that OSF already has in place could be utilized to care for these patients in their homes, thereby freeing up hospital capacity.

"We haven't executed on any of that yet, but we are certainly identifying additional ways that we can serve patients with the waiver or without the waiver," Clark said.

"OSF is committed to our hospital-at-home program and is committed to continuing to find ways to serve patients in this model," she continued.

Anuja Vaidya has covered the healthcare industry since 2012. She currently covers the virtual healthcare landscape, including telehealth, remote patient monitoring and digital therapeutics.

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