The Centers for Medicare & Medicaid Services (CMS) recently updated guidance for evaluating critical access hospital (CAH) compliance with federal rural status and distance requirements. The guidance establishes a more standardized nationwide review process and supersedes CMS guidance issued in 2016, effective Sept. 20.
Beginning in 2033, the CMS will review all existing CAHs every 10 years to assess continued compliance with rural status and distance requirements. Reviews may also be triggered when a new acute care hospital is certified near an existing CAH, or when a hospital seeks certification or conversion to CAH status.
The guidance also directs CAHs to add a provider-based location (PBL). The CMS recommends that CAHs seek an advance determination from the CMS regional office before adding a PBL to confirm that the new site will not adversely affect the CAH’s distance eligibility.
The guidance clarifies that psychiatric, rehabilitation and long-term care hospitals will not be considered acute care hospitals for purposes of CMS distance requirements. The CMS also issued additional guidance on verifying Necessary Provider designations, which remain exempt from federal distance requirements if designated before Jan. 1, 2006.
Separately, the guidance streamlines the survey process. State survey agencies and CMS-approved accrediting organizations may now conduct a CAH’s recertification survey on its existing schedule without first obtaining CMS confirmation of rural and distance eligibility.
The CMS will notify CAHs found out of compliance and generally allow them time to reclassify as rural, convert to another provider type, including rural emergency hospital status when eligible, or otherwise address the determination.
The changes may be most relevant to hospitals pursuing CAH conversion, providers near newly certified acute care hospitals and organizations with historic Necessary Provider designations. The MHA will monitor implementation and share Michigan-specific information as it becomes available.
Members with questions may contact Caroline Stoner at the MHA Center of Rural Excellence.
Phone: (517) 703-8601
Fax: (517) 703-0628
