MDHHS Releases REHs Medicaid Reimbursement Final Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a final policy to establish Medicaid reimbursement for rural emergency hospitals (REHs) effective Jan. 1, 2023. The MDHHS reimburses REHs based on the existing outpatient prospective payment system (OPPS) methodology. Critical access hospitals (CAHs) that convert will continue to be paid using the enhanced OPPS reduction factor, while non-CAHs will continue to be paid using their existing OPPS reduction factor. REHs must update their enrollment and subspecialty with the MDHHS through the Community Health Automated Medicaid Processing System (CHAMPS) provider enrollment system within 35 days of any change. Hospitals that convert to REHs must end date their inpatient specialty.

Members with questions regarding the policy should contact Vickie Kunz while members that need assistance evaluating potential conversion should contact Lauren LaPine at the MHA.

Rural Emergency Hospital Webinar on Requirements and Conversion Process

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.

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.

 

 

 

 

 

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.