New Jersey Licenses and Regulates Mobile Integrated Health Programs
New Jersey recently licensed its first Mobile Integrated Health (MIH) program, which allows licensed paramedics and EMTs to deliver non-emergency clinical services to patients in their homes, following the adoption of regulations governing such programs earlier this year. Similar programs, also called community paramedicine programs, are being implemented in other states across the country, with providers showing an increased interest in providing health care to patients outside of the hospital setting.
Per the Centers for Disease Control, an estimated 40% of emergency room visits involve patients who present with a non-urgent medical issue or condition, many of which could be prevented if the patient had received health care services at an earlier date. MIH programs offer access to health care outside of the emergency room and are intended to help pare down emergency room visits. Those in rural areas, post-discharge patients, geriatric patients, patients with comorbidities, or those who are medically underserved stand to benefit the most from MIH. These programs provide primary and preventive care, post-discharge care, health education and coaching, chronic disease management, personalized in-home care and public health emergency responses, all at a projected lower cost for health systems. The MIH program will coordinate care among the patient’s other health care providers, theoretically resulting in an overall healthier patient who will be less likely to visit an emergency room.
New Jersey joined other states in formally recognizing such programs when it codified its MIH program regulations at N.J.A.C. 8:49, which were effective immediately. The regulations require that a New Jersey MIH program be licensed, and limits eligibility to hospitals licensed by the New Jersey Department of Health (DOH) to operate a mobile intensive care agency. Applicants will be evaluated based on their ability to protect patient health, safety and wellness, as well as their prior history of compliance with applicable laws. DOH will evaluate an applicant’s track record of operating other health care facilities both in New Jersey and any other state in which it, or any affiliates or subsidiaries, operates. If an application is approved, DOH may conduct a pre-licensure on-site inspection of the MIH program premises, personnel, equipment, procedures and finances.
An MIH license applicant must pay a $10,000 fee for an initial licensure application and a $2,500 fee for an initial authorization application for each MIH program service type. The term of an MIH license will be two years and must be renewed. The renewal applicant must pay a $5,000 renewal fee and a $1,250 fee for renewal authorization of each service type. The regulations authorize DOH to assess monetary penalties or implement other enforcement actions against MIH programs that are not in compliance with the various requirements set forth in the regulations, including those governing personnel qualifications, recordkeeping, quality assurance and improvement, patient transportation, and emergency events.
MIH programs are expanding across the United States with health systems looking for various ways to provide access to health care services to populations that are difficult to reach or that need regular visits from a health care provider. Several health systems have implemented hospital at home programs, as previously noted, and are now building on that model by implementing MIH programs in an effort to fill gaps in health care and keep certain patient populations out of the hospital. DOH stated that it is currently reviewing other MIH program applications, and it is expected that more programs will be licensed in New Jersey in the coming weeks and months.
