Rural Emergency Hospital Legislation Passed in Michigan

The legislation needed for hospitals to begin converting to Rural Emergency Hospitals (REH) in Michigan was sent to the Governor’s desk Dec. 6 for final approval. Due to limited session days left, the language to allow for REH licensure in Michigan was officially included in Senate Bill (SB) 183. After the REH amendments were adopted, SB 183 passed with overwhelming support in both the State House and Senate.

The MHA has been actively working with the Michigan Department of Health and Human Services, the Michigan Department of Licensing and Regulatory Affairs (LARA) and the Whitmer administration’s legal team on REH licensure during the legislative process and have received positive indications of the administration’s support for SB 183.

Member hospitals considering conversion to an REH are encouraged to review the final rules by the Centers for Medicare and Medicaid Services (CMS). Some key changes outlined in the final rule include:

  • Clarification that REHs can operate provider-based rural health clinics (RHCs) and that REHs are considered hospitals with less than 50 beds for purposes of the payment limit exception. Provider-based RHCs will maintain their excepted status upon a hospital’s REH conversion.
  • A roughly $4,000 per month increase in monthly facility payments due to a misstep in the methodology that the National Rural Health Association (NRHA) highlighted in the MHA comment on the proposed rule.
  • The CMS agreed with the NRHA that one-lane federal highways should be excluded from the definition of primary roads. Primary roads are now defined as state or federal highways with two or more lanes in either direction.

Additionally, the CMS has released initial information on the application process. There will also be an application process at the state level through LARA. This application is still in development.

Members considering converting to the REH designation should contact Lauren LaPine at the MHA for support in navigating this process.