Hospitals interested in learning more about the new Rural Emergency Hospital (REH) designation are encouraged to attend an upcoming webinar from 12:30 p.m. to 2 p.m. ET Jan. 18 hosted by Mathematica and the Rural Health Redesign Center (RHRC) for an overview of the REH designation.
Participants will learn about REH requirements and the Centers for Medicare and Medicaid Services’ conditions for REH participation and payment. Presenters will also describe how the RHDC and its partners can assist entities through the REH conversion process and access ongoing transition support.
There is no cost to participate, but registration is required. Members with questions about the REH designation should contact Lauren LaPine.
Critical Access Hospitals (CAHs) that accept Medicare and Medicaid payments must follow the Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoP). The CMS CAH Manual has seen multiple changes to regulations and interpretive guidelines. The MHA Health Foundation five-part webinar series Critical Access Hospitals’ Conditions of Participation: Ensuring Compliance will review in detail the guidelines that serve as a basis for determining compliance.
Topics that will be covered in detail include:
- CMS requirements of the board’s duty to enter into a written agreement if the hospital wants to provide telemedicine services.
- CMS list of emergency drugs and equipment that every CAH must have.
- Requirements for pharmacists, including development, supervision and coordination of pharmacy activities.
- Requirements for security and storage of medications, medication carts and anesthesia carts.
- CMS infection control worksheet and how it may be helpful to CAHs.
- Hospital visitation and patient information policies.
The webinars are scheduled from 10 a.m. to noon Jan. 17, Jan. 24, Jan. 31, Feb. 7 and Feb. 14. Members can register for a connection fee of $780 for the series. Individual webinars are $195 per session.
Members with questions should contact Erica Leyko at the MHA.
After the MHA’s recent visits to Capitol Hill to advocate for year-end member priorities, Congress has reached a major deal on a year-end omnibus legislative package. The package includes health policy measures related to Medicare and Medicaid provisions, telehealth and hospital-at-home programs.
Lawmakers are blocking the implementation of the Statutory Pay-As-You-Go (PAYGO) sequester which would have required a 4% cut to Medicare payments. In addition, both the Medicare Dependent Hospital and enhanced low-volume adjustment programs are extended for two years. The Medicare hospital-at-home program and pandemic-era telehealth flexibilities are also extended for two years. There is a one-year delay in lab payment changes stemming from the Protecting Access to Medicare Act of 2014.
Regarding Medicaid, the package separates the enhanced federal medical assistance percentage (FMAP) and the Medicaid eligibility maintenance of effort from the declaration of the Public Health Emergency. Beginning in April, states may remove those who no longer qualify for Medicaid, regardless of when the COVID-19 public health emergency ends. The enhanced FMAP, currently a 6.2% addition to state Medicaid matching rates, is gradually phased out through 2023. These changes help fund a year of continuous coverage provisions for children at risk of losing health insurance and standardizing 12 months of postpartum coverage.
Passage of the final legislation is likely to happen by midnight on Dec. 23, 2022. The bill text is public, giving high likelihood to the healthcare provisions outlined above. However, there is a possibility for last-minute changes.
For more information about the year-end omnibus legislation contact Laura Appel at the MHA.
Critical access hospitals (CAHs) that accept Medicare and Medicaid payments must follow the Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoPs). The CMS Critical Access Hospital Manual has seen multiple changes to regulations and interpretive guidelines. Since a hospital’s payment is based on compliance with the conditions, it is imperative hospitals make the necessary changes to remain in compliance.
The MHA Health Foundation webinar series Critical Access Hospitals Conditions of Participation: Ensuring Compliance is a five-part series that will review in detail the updated requirements and changes for CAHs. The webinars are scheduled for Jan. 17, 24, 31, Feb. 7 and 14 from 10 a.m. to noon.
Members can register for individual sessions for $195 or the full series for $780.
Members with questions should contact Erica Leyko at the MHA.
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.
The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to modify the prior authorization process for certain payers. The proposal would require payers to:
- Include a specific reason when denying a request.
- Publicly report certain prior authorization metrics.
- Make decisions within 72-hours for urgent requests.
- Make decisions within seven days for standard, non-urgent requests, which is twice as fast as existing Medicare Advantage response timelines.
- Enable improved data exchange.
The proposal generally applies to Medicare Advantage, Medicaid and Medicaid managed care and Children’s Health Insurance Program (CHIP) and CHIP managed care plans, as well as qualified health plans on the federally facilitated exchanges. Members are encouraged to review the proposal and submit comments to the CMS by the March 13, 2023 deadline.
Members with questions should contact Jason Jorkasky at the MHA.