Why Complete Care Cannot Accept Medicare Benefits

Complete Care is committed to providing high-quality emergency care to all patients in our Texas and Colorado communities. However, due to federal regulations, we cannot currently accept Medicare, Medicaid, or Tricare benefits at our freestanding emergency room locations.

This isn’t unique to Complete Care. State-licensed freestanding emergency centers nationwide cannot qualify for Medicare recognition because the Centers for Medicare & Medicaid Services (CMS) does not recognize them as provider-based facilities.

We’re working to change this. Complete Care’s CEO, Robert Morris, has served as President of the National Association of Freestanding Emergency Centers (NAFEC) board of directors for two years after previously serving on the Texas Association of Freestanding Emergency Centers (TAFEC) board. Through congressional advocacy, we’re fighting for policy change — and we need your help.

In this video, Rob discusses the Medicare and Medicaid reimbursement barriers and what we can do to help. 

KEY TAKEAWAYS:

• State-licensed freestanding emergency centers (FEC) don’t qualify for Medicare recognition.
• The CMS does not recognize freestanding ERs as provider-based facilities.
• Complete Care, a FEC, does not currently accept Medicare, Medicaid, or Tricare benefits.
• Complete Care CEO Rob Morris is actively fighting for federal policy change that would allow freestanding ERs to accept these benefits.
• Contact your legislators to help pass the Emergency Care Improvement Act (HR 3134).

Below, we’ve answered common questions about Medicare coverage at freestanding emergency rooms and how you can support efforts to expand access to emergency care for all Americans.

Does Medicare cover freestanding ER visits?

Currently, Medicare does not cover visits to state-licensed freestanding emergency centers like Complete Care. This restriction applies to all freestanding ERs nationwide, not just Complete Care locations.

CMS only recognizes hospital-based emergency departments and hospital-affiliated emergency rooms as eligible Medicare providers. Because freestanding emergency centers operate independently and are not attached to hospitals, they do not qualify for Medicare reimbursement under current federal regulations.

Does Complete Care take Medicare?

No, Complete Care cannot currently accept Medicare, Medicaid, or Tricare benefits due to federal regulations that prevent state-licensed freestanding emergency centers from qualifying for recognition by the Centers for Medicare & Medicaid Services (CMS).

This is not a choice — it’s a federal policy limitation that affects all freestanding emergency rooms across the United States. We want to serve Medicare and Tricare beneficiaries, just as we did during the Public Health Emergency waiver period. However, until federal law changes, we are unable to accept these government insurance programs.

Why were freestanding ERs able to accept Medicare during COVID?

During the COVID-19 Public Health Emergency from April 2020 to 2023, freestanding emergency centers were granted a temporary waiver that allowed them to become Medicare-certified providers. 

During those three years, Complete Care successfully treated Medicare patients and submitted hundreds of thousands of claims. As Rob mentions in his Texas Talks interview, data collected by the NAFEC during this period showed that freestanding ERs were 21% cheaper than hospital-affiliated emergency rooms without increasing utilization — proving that FECs can deliver high-quality, cost-effective emergency care to Medicare beneficiaries.

When the Public Health Emergency ended, so did our ability to serve Medicare patients. By helping to pass the Emergency Care Improvement Act, we can provide Medicare patients with the care they deserve.

What are Texas freestanding ER regulations?

In Texas, freestanding emergency centers are regulated by the Texas Department of State Health Services (DSHS) and must meet strict licensing requirements to operate. Texas freestanding ERs must:

• Maintain the same equipment, staffing, and clinical standards as hospital emergency departments
• Be staffed 24/7 by board-certified emergency physicians and licensed nurses
• Provide on-site laboratory and diagnostic imaging services
• Meet facility standards for patient safety and quality of care
• Comply with state health and safety inspections

Complete Care exceeds these state requirements at all of our locations. We provide the same level of emergency care you would receive at a hospital ER, with shorter wait times and a more convenient, patient-focused experience.

Despite meeting or exceeding all state regulations and clinical standards, Texas freestanding ERs — like those in other states — still cannot qualify for Medicare recognition under federal law.

What can I do to help freestanding ERs accept Medicare?

You can make a difference by contacting your U.S. Representative and asking them to support the Emergency Care Improvement Act (HR 3134). This bipartisan legislation would allow state-licensed freestanding emergency centers to qualify for Medicare and Tricare recognition, giving millions of Americans greater access to timely, cost-effective emergency care.

How to contact your legislator:

1. Find your U.S. Representative at www.house.gov/representatives/find-your-representative
2. Call or email their office 
3. Ask them to support HR 3134, the Emergency Care Improvement Act (you can find scripts online!)

Expanding Medicare coverage to freestanding emergency centers would:

• Increase access to emergency care in underserved communities
• Reduce wait times for all patients
• Lower healthcare costs for taxpayers
• Provide more options for emergency medical treatment

Your voice matters. Together, we can help ensure that all Americans — regardless of their insurance — have access to the emergency care they need, when they need it.

We’re here for you — and we’re fighting for change

While we cannot currently accept Medicare benefits, Complete Care remains committed to providing exceptional emergency care to our communities in Texas and Colorado. 

We continue to advocate at the federal level for policy changes that would allow us to serve Medicare and Tricare beneficiaries once again. Please help us with this important effort by contacting your U.S. Representative today.

If you have questions about insurance coverage, billing, or payment options, please contact us at any of our locations or call our patient services team.