CAHs in Danger of Not Meeting CMS Distance Requirements if Required to Re-Enroll in Medicare

The Office of Inspector General (OIG) issued a report this week, recommending the Centers for Medicare and Medicaid Services (CMS) seek legislative authority to remove necessary provider (NP) Critical Access Hospitals (CAHs) permanent exemption from the programs distance requirement and revise conditions for participation. This report, titled "Most Critical Access Hospitals Would Not Meet the Location Requirements If Required to Re-enroll in Medicare" bases its recommendations upon a study conducted by OIG, which found "nearly two-thirds of the nation's CAHs would not meet the location requirements if required to re-enroll."

OIGs Recommendations:

1. Seek legislative authority to remove NP CAHs' permanent exemption from the distance requirement, thus allowing CMS to reassess these CAHs;
2. Seek legislative authority to revise the CAH Conditions of Participation to include alternative location-related requirements;
3. Ensure that it periodically reassesses CAHs for compliance with all location-related requirements; and
4. Ensure that it applies its uniform definition of "mountainous terrain" to all CAHs.

According to the report, CMS has concurred with OIGs first, third, and fourth recommendations, but did not concur with the second recommendation. Click here to download the full report.

CAHs are no stranger to regulatory pressures that seek to jeopardize their financial viability and the quality of care they are able to provide their community. There are several actions you can take to help preserve access to health care in rural America, including working with your Congressional leaders to preserve your rights and access to this program. CAHs provide necessary access to primary and preventative care in rural America. They excel in coordinating care in a manner that has proven to deliver lower per beneficiary costs. We need to work diligently to protect our patients' access to quality health care.  

The National Rural Health Association is presenting 10 regional meeting starting on August 20^th in Seattle, WA to assist rural hospitals in weighing the factors when planning their ability to serve the future health care needs of their communities. Eide Bailly representatives will be presenting a session surrounding how you can strategically position your CAH under health care reform. Click here to learn more about these meetings dedicated to preserving community hospitals.

While the future remains uncertain, now is the time to strategically plan the future of health care in your community, and evaluate the potential impact the loss of CAH status would have on your hospital and community.

Please contact Ralph Llewellyn or your Eide Bailly representative to evaluate your options.