Rural Health Research Gateway Releases Report on the First Year of REHs

The Rural Health Research Gateway recently published a report on Rural Emergency Hospitals (REHs) highlighting data from the first year of the designation. Under the Consolidated Appropriations Act of 2021, the Rural Emergency Hospital provider type was created to address rural hospital closures. There is one REH in the state of Michigan, Sturgis Hospital located in Sturgis, MI. Additionally, there are 18 other REHs across the country (four REHs in Texas, three in Mississippi, three in Oklahoma, two in Arkansas, two in Georgia, and one in each of Kansas, Louisiana, New Mexico and Tennessee).

The report found that a majority of the REHs operating at the end of 2023 were in the south. The brief also found that REHs tend to serve under resourced counties that face a myriad of challenges, such as increased poverty and uninsured rates, along with a shortage of primary care and mental health providers. Counties with REHs also tend to have higher rates of premature deaths. These findings suggest that counties with REHs are facing more severe challenges than their other rural counterparts.

As REHs continue into their second year, further monitoring will provide more information on the long-term impact of REHs on healthcare outcomes in rural areas.

Members with questions may contact Lauren LaPine at the MHA.

CMS Releases Medicare 2025 Outpatient Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service outpatient prospective payment system (OPPS) effective Jan. 1,  2025.

The proposed rule:

  • Provides a net 2.3% increase to the OPPS conversion factor from $87.38 to $89.38 for hospitals that report quality measure data.
  • Increases the outlier fixed-dollar threshold by 3.2% from the current $7,750 to $8,000.
  • Modifies the timeframe for standard review of prior authorization requests for hospital outpatient department services from 10 business days to seven calendar days.
  • Uses 2023 claims data and the most updated cost report data from the healthcare cost report information system, primarily from 2022, to set payment rates.
  • Adds three services (CPT codes 0894T, 0895T and 0896T) for liver allograft-related procedures to the 2025 Inpatient-Only List.
  • Updates the core based statistical areas used to determine a hospital’s wage index, consistent with other 2025 proposed rules.
  • Adds two new status indicators (H1 and K1) to identify healthcare common procedure coding system/current procedural terminology (HCPCS/CPT) codes representing separately payable, non-opioid post-surgical pain management products as authorized by the Consolidated Appropriations Act of 2023.
  • Establishes separate payment for diagnostic radiopharmaceuticals with a per-day cost exceeding $630.
  • Excludes qualifying cell and gene therapies from comprehensive ambulatory payment classification packaging.
  • Adopts three measures related to health equity for the Outpatient, ambulatory surgical center (ASC) and rural emergency hospital quality reporting programs, and extending voluntary data reporting for two hybrid measures in the inpatient quality reporting program.
  • Establishes new conditions of participation for hospitals and critical access hospitals focused on obstetrical services and maternal care.
  • Extends the virtual direct supervision of therapeutic and diagnostic services under the physician fee schedule (PFS) through Dec. 31, 2025. The CMS also proposes to extend virtual direct supervision under the OPPS through Dec. 31, 2025, to maintain alignment between the PFS and OPPS.
  • Adds 20 medical and dental procedures to the ASC covered procedures list.
  • Updates the hospital outpatient quality reporting program requirements.
  • Updates requirements for the rural emergency hospital quality reporting program.

The MHA will provide a hospital-specific impact analysis within the next few weeks and encourages members contact Vickie Kunz by Aug. 30 regarding issues identified. Hospitals are encouraged to review the proposed rule and its impact on operations and submit comments to the CMS by Sept. 9.  The CMS is expected to release a final rule around Nov. 1 for the Jan. 1, 2025, effective date.

Members with questions may contact Vickie Kunz at the MHA.

MHA Monday Report May 20, 2024

Legislature Advances MHA Supported Policy Bills; Budgets Moves Through Senate

The Michigan Senate advanced their chamber budgets for the upcoming fiscal year during the week of May 13. The Senate’s budget recommendations for the Department of Health and Human Services continues vital funding for Medicaid, …


House Campaign Committee Chairs Address Legislative Policy Panel

The MHA Legislative Policy Panel met at the MHA Capital Advocacy Center May 15 to develop recommendations for the MHA Board of Trustees on legislative initiatives impacting Michigan hospitals. The meeting was highlighted by presentations …


CDC Urges Hospitals to Complete mPINC Survey

The 2024 Centers for Disease Control and Prevention (CDC) national survey of Maternity Practices in Infant Nutrition and Care (mPINC) will close June 10. The CDC seeks to assess maternity care practices that influence how …



Rural Emergency Hospital Improvement Act Introduced in the U.S. Senate

U.S. Sens. Jerry Moran (R-KS) and Tina Smith (D-MN) introduced the Rural Emergency Hospital Improvement Act May 14 to bolster rural healthcare. Senate Bill 4322 aims to address critical gaps in rural healthcare infrastructure by …


MHA Podcast Explores Benefits, Challenges of Virtual Care in Behavioral Health

The MHA released a new episode of the MiCare Champion Cast exploring how clinicians are navigating virtual care in the behavioral health space. The episode, released during Mental Health Awareness Month, features two providers from Pine Rest Christian Mental Health Services. …


The Keckley Report

Hospitals at a Crossroad: Reactive Navigation or Proactive Orchestration?

“The U.S. economy is strong but growing numbers in the population face financial insecurity and economic despair. Increased out-of-pocket costs for food, fuel and housing (especially rent) have squeezed household budgets and contributed to increased medical debt—a problem in 41% of U.S. households today. Hospital bills are a factor. …

For most hospitals, a decision to invest and behave as if the future is a repeat of the past is a calculated risk. Others with less stake in community health and wellbeing and greater access to capital will seize this opportunity and, in the process, disable hospitals might play in the process.

Near-term reactive navigation vs. long-term proactive orchestration–that’s the crossroad in front of hospitals today. Hopefully, during National Hospital Week, it will get the attention it needs in every hospital board room and C suite. …”

Paul Keckley, May 12, 2024


News to Know

The Michigan Department of Licensing and Regulatory Affairs is requesting feedback to understand the challenges of obtaining a license.


MHA CEO Brian PetersMHA in the News

Crain’s Grand Rapids published an article May 16 on the release of Rand Corp. study on hospital pricing. Michigan reportedly has the third lowest hospital care costs relative to Medicare in the country, although the …

Rural Emergency Hospital Improvement Act Introduced in the U.S. Senate

U.S. Sens. Jerry Moran (R-KS) and Tina Smith (D-MN) introduced the Rural Emergency Hospital Improvement Act May 14  to bolster rural healthcare. Senate Bill 4322 aims to address critical gaps in rural healthcare infrastructure by incorporating several technical improvements to the Rural Emergency Hospital (REH) statute. The National Rural Health Association (NRHA) expressed support over the proposed legislation, noting that it incorporates key suggestions brought forward by its members. Among the key provisions outlined in the bill are measures to facilitate the reopening of previously closed rural hospitals. Under the proposed legislation, these hospitals could apply for REH designation if they can demonstrate compliance with eligibility requirements between Jan. 1, 2015, and Dec. 27, 2020.

Additionally, the bill directs the Secretary of Health and Human Services (HHS) to establish a waiver program to allow facilities operating similarly to an REH to convert to this designation. This move aims to expand the reach of REHs and ensure more communities can benefit from their services. The bill addresses other keys, such as expanding the scope of care to include psychiatric, obstetric and rehabilitation services. It also seeks to enhance funding for REH facilities, clarify their eligibility for grants and improve workforce recruitment by authorizing them as National Health Service Corps sites. Furthermore, the bill streamlines patient transfers and offers flexibility for facilities to revert to Critical Access Hospital status, if needed.

Members with questions may contact Lauren LaPine at the MHA.

The Rural 340B Access Act of 2024 Introduced in the U.S. House

*This article was updated May 14 to accurately reflect current 340B eligibility requirements. 

The bipartisan Rural 340B Access Act of 2024 was introduced April 29 in the U.S. House of Representatives. Introduced by Reps. Jack Bergman (MI-01) and Debbie Dingell (MI-06), the legislation aims to enhance the Rural Emergency (REH) designation and ensure the continued operation of emergency department in rural areas through the expansion of 340B eligibility.

The Rural 340B Access Act addresses a previous oversight by Congress during the designation process, which excluded REHs from eligibility for the 340B drug discount program. This program is crucial for rural providers, including 20 hospitals in district 1 in Michigan.

The National Rural Health Association, the American Hospital Association and the MHA support this legislation.

Members with questions may contact Lauren LaPine at the MHA.