Hello all,
I wanted to make sure you knew about these CMS regulations in case we
wanted to make comments on these proposed rule changes. If you have
already received this, please disregard.
The following rules will impact rural and urban areas-
Payment changes in the way it calculates reasonable cost, taking
away Medicare co-pays and Medicaid payments so as to not exceed the 80%
cap. Currently, you can get both the reasonable cost up to 80%, and the
co-pays.
For rural areas-
To continue participation in the Medicare FQHC program, rural FQHC's
will need to do the following
Implement an infection control plan
Emergency services and training- updating the requirements for the
current industry standards, including requirements about the purchase of
equipments.
Below is the link to the National Rural Health Association's web link.
Following is the article, with direct links to the CMS documents.
I will be reading this in more detail, but wanted to give you this
information.
Let me know your opinion on adding this to the next FDR meeting to
discuss.However, our comment time deadline may be August 27th, so our
August 22nd meeting may be cutting it close.
Thanks
Amy
http://www.ruralhealthweb.org/go/rural-health-news/cms-releases-rhc/fqhc
-regulations
CMS Releases RHC/FQHC Regulations
The Centers for Medicare and Medicaid Services (CMS) has published a
proposed rule impacting Rural Health Clinic (RHC) and Federally
Qualified Health Center (FQHC) operations. The proposed rule is now
available here
<
http://www.ruralhealthweb.org/index.cfm?objectid=FACCE155-1185-6B66-88B
3A3C3EA6B0CB9> online
NRHA staff is beginning our review of the proposed rule. A first review
indicates that CMS is revising location requirements and designation
exceptions. It also appears to be adding a requirement for RHCs to
obtain or renew their designation every three years. In addition, the
proposed rule would require new conditions of participation for clinics
in the RHC program and change the calculation of payment rates for RHCs
and FQHCs. A brief summary of the proposed rule follows:
Highlights of the proposed rule
Our initial review indicates the following highlights from the proposed
rule:
RHC location requirement for designation - RHCs must be located in
rural, underserved areas to obtain their designation.In the past, once
an RHC was designated, they were allowed to keep their RHC status
permanently.CMS is changing this, requiring an RHC to renew their
designation every three years provided their service area still is in a
rural area and meets the shortage designation requirements.In addition,
CMS is changing the way it defines rural, now using the Rural Urban
Community Areas (RUCA) designations.There are a couple of technical
exceptions to this provision that will be detailed in the forthcoming
NRHA RHC Regulatory Guide.
* Payment change for RHCs and FQHCs - CMS is proposing a change to
the way it calculates reasonable cost in their cost-based reimbursement
rates for these providers.Currently the law says payments cannot exceed
80 percent of reasonable cost.However, in many instances RHCs and FQHCs
can receive more than 100 percent of reasonable costs if they also
receive co-pays or Medicaid supplements.This will no longer be allowed.
* Requirements to waive payment cap for provider-based RHCs - CMS
is proposing changes to those hospitals that qualify to waive the
payment cap for provider-based RHCs. These facilities will need to be
located in an area with a RUCA score of 9 or 10 and be under 50 beds for
their average daily census.This may allow more provider-based facilities
to waive the payment cap.
* New requirements for participation - CMS is proposing that RHCs
have to implement the following quality programs to remain an RHC:
* Quality Assessment and Performance Improvement Program -
All RHCs would have to implement a quality improvement program with
objective measures, adoption of performance measures and a plan to
identify priorities.
* Infection Control plan - Both RHCs and FQHCs would be
required to create and implement an infection control plan, including
training, oversight and reporting of staff conducting clinical
activities that control infections.
* Emergency services and training - RHCs and FQHCs are
already required to provide services in medical emergencies. This
proposed rule would update the requirements for the current industry
standards, include requirements around the purchase of equipment but
eliminate the current prescriptive drug list.
The NRHA was listed by CMS as one of the resources for these quality
programs in the proposed rule. Stay tuned to our web site and
conferences for technical assistance in implementing the new
requirements in the proposed rule.
The rule has a number of other payment and participation requirements
that NRHA is reviewing. We will continue to update NRHA members on how
this proposed rule will impact the health of rural Americans. For now,
more information is available from CMS:
* Proposed rule
<
http://www.ruralhealthweb.org/index.cfm?objectid=FACCE155-1185-6B66-88B
3A3C3EA6B0CB9>
* Press release
<
http://www.cms.hhs.gov/apps/media/press/release.asp?Counter=3174&intNum
PerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchDa
ta=&keywordType=All&chkNewsType=1%2C+2%2C+3%2C+4%2C+5&intPage=&showAll=&
pYear=&year=&desc=&cboOrder=date>
* Fact sheet
<
http://www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=3175&intN
umPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srch
Data=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=
&cboOrder=date>
More on the regulatory process
Whenever the federal government makes a regulatory change, the agency
responsible for the change must offer the general public an open comment
period to express their views on the proposed regulation. The agency
must then respond to each of these comments. For this proposed rule
comments must be received by CMS 60 days after publication in the
Federal Register, which we expect to be Aug. 27, 2008. This is the
second time CMS has proposed an overhaul of the RHC program. In 2003,
they were forced to withdraw a final rule. Rural advocates need to again
pay significant attention to these proposed changes, as they could have
a significant impact on the main primary care providers in rural
communities, especially RHCs.
Amy Sawaya
Workforce/ Utah Search Program Coordinator
Association for Utah Community Health (AUCH)
860 East 4500 South, Suite 206
Salt Lake City, UT 84107
Direct line: 801-716-4610 NEW DIRECT LINE
Phone: 801-974-5522
Fax: 801-974-5563
Email: workforce@??? <mailto:workforce@???>
