Member Feedback Requested on Rural Emergency Hospital Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule June 30 that would establish conditions of participation (CoPs) that Rural Emergency Hospitals (REHs) must meet to participate in the Medicare and Medicaid programs. This proposed rule also includes changes to the Critical Access Hospital CoPs. Proposed payment and enrollment policies, quality measure specifications and quality reporting requirements for REHs will be included in future rulemaking. The CMS also modifies the provider agreement regulations to include REHs. The public comment period will end Aug. 29.

The MHA has been working closely with the Michigan Department of Health and Human Services (MDHHS) and the Michigan Department of Licensing and Regulatory Affairs (LARA) over the past few months to develop the licensure criteria and conversion process for eligible facilities in Michigan to convert to an REH after Jan. 1, 2023. The MHA will develop a comment letter in response to the proposed rule and share a draft with small/rural members prior to submission. To include input from Michigan hospitals eligible to convert to an REH in its comments, the MHA has created a brief survey to collect critical feedback that should be submitted by Aug. 1. Members with questions or concerns are encouraged to contact Lauren LaPine at the MHA.

Peters Expresses Support for Implicit Bias Training Requirement

Brian Peters

Brian PetersMHA CEO Brian Peters expressed the MHA’s support for the Michigan Department of Licensing and Regulatory Affair’s new implicit bias training requirement for all professions licensed or registered under the Public Health Code in a story by Michigan Capitol Confidential.

Peters cited the training as the next step in the MHA’s long history of safety and quality improvement work by hospitals led through the MHA Keystone Center. Peters also mentioned that many hospitals in the state have already been offering an implicit bias training prior to the requirement.

“Yes, we might require some time for our clinicians or employees to do this training,” said Peters. “But if we avoid rehospitalizations, if we avoid complications that require an extended hospital stay, we’re going to save them time on the back end by having better outcomes.”

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