Rural Health Clinics

Situation Moderated in West Virginia

Still a Cautionary Tale for RHCs Everywhere!

In our last newsletter, we reported on a disturbing situation in West Virginia involving Medicaid payment for Rural Health Clinics in that state.


The West Virginia Medicaid program was sued by a group of FQHCs who argued that the state was unfairly paying them for services they were providing to West Virginia Medicaid recipients. The court ordered the state to relook at the way Medicaid payments were determined & work out a compromise with the FQHCs. 


In addressing the FQHC complaint, the state opted to revise not only the way the state paid FQHCs but also the way the state paid RHCs. According to RHCs that contacted NARHC, the financial ramifications would be devastating. In the case of one RHC, the clinic would experience a $20.00 per visit reduction in Medicaid payments & owe the state hundreds of thousands of dollars in back payments. read more 

Letter from the NARHC Executive Director   

Preventive Services Ruling Rescinded

by Bill Finerfrock

August 18, 2014:  CMS formally announced that they were rescinding a policy adopted earlier this year which denied payment for certain preventive services provided as stand-alone services when delivered in the RHC setting.  


This change in policy by CMS comes about after intense pressure from NARHC, our members and friends and our bi-partisan Congressional Allies. I want to thank all of you who took the time to contact your Congressional offices to make them aware of the impact the change in policy was having on you and your patients.  While this is an important victory for the RHC community, it is even more important for your patients!


When the RHC Community acts together & engages our allies, we can successfully advocate for policy changes that improve your ability to provide quality healthcare & the ability of your community to enjoy a better quality of life.   read more 

NARHC 2014 Fall Institute
A conference "For and About" RHCs

22 Sessions, 13 Breakouts

Legislative Update                   Stage 2 Meaningful Use

Survey & Recertification         Ask the Experts      

Starting a New RHC                RHC Acquisition:       

The RHC Early Years              --Transaction, Asset Valuation, Phys Comp   

RHC Basic Billing                     --Change of Ownership (CHOW)  

RHC Advanced Billing             Medicare/Medicaid Rate Setting  

Insurance Credentialing          Establishing Quality:   

Cost Reporting                        --Steps To PCMH    

Management Issues                --Q.I., Initiatives, Patient Satisfaction   

Allergy Shots, Hep Vaccine    Practice Management  

All Things Compliance             MAC Discussions


Hurry! Registration rates increase a month before the conference. 
Also the last day to reserve a $79 room is Sept. 22 (or before if block fills)!

Earn CEU credit (AAFP, AANP, AAPC). 
read more

2015 Membership Sale

BIG SAVINGS for 1st-Time Members to Check Us Out!

If your clinic is a 1st-time NARHC member, join now to receive the remaining months of 2014 (free) plus all 12 months of 2015 for the one-year price! The 1st-time rate is also discounted! Associations, Consultants and Governmental entities are also welcome to join, however, the sale is just for 1st-time RHCs. For rates see the Membership Application. If unsure of member status, call us at 866-306-1961 for a quick lookup.

NARHC also offers a group discount (add. RHCs after the first join for $130 ea.) & discounted Joint Memberships with 3 State Assns (CA, MO, TX)! read more 

Shortage Designation Processing


On August 31, HRSA decommissioned its online shortage designation processing system.  The new system will be available mid-December.  In preparation for this transition, earlier this year HRSA urged state Primary Care Offices to identify and prioritize shortage designations needed for Rural Health Clinic and other certifications.  All existing Health Professional Shortage Areas remain through December 2014, when new applications will be able to be submitted through the new online system.  Any rural providers concerned with shortage designation processes are encouraged to contact their state Primary Care Office.

MSP Questionnaire

Complete one for every patient visit?

One of the MACs will be conducting 90 on-site MSP audits starting this Fall.  At the RHC conference in Texas, a representative from one of the MAC's (Novitas) stated that they expect the MSP questionnaire to be completed for every patient visit. When asked if it was necessary for the long form to be completed for every patient visit, guidance was given that certain questions must be asked, but it does not state that a written form has to be completed every visit. The MAC representative also indicated that the retention period for MSP information is 10 years read more 

In case you missed it...
Recent CMS Regulation Updates

42 CFR PART 491 AND G0101 & G0105

C.4. RHCs/FQHCs, 42 CFR Part 491 (Effective: July 11, 2014)


Staffing and Staff Responsibilities, 491.8   

  • 491.8(a)(3) was revised to permit an RHC to have a nurse practitioner or physician assistant provide services under contract to the RHC, so long as the RHC has at least one employee who is a nurse practitioner or physician assistant. This change was effective July 1, 2014.
  • 491.8(a)(6) was revised to require for RHCs that a nurse practitioner, physician assistant, or certified nurse-midwife is available to furnish patient care services at least 50% of the time the RHC operates. This aligns the regulatory language with the current statutory requirement. Note that since the statutory provision was self-implementing, CMS has enforced the 50% standard even prior to this regulation change. (See S&C 09-14)  read more
NARHC Board of Directors

There are five candidates for three openings on the NARHC Board of Directors. These positions will be voted upon by the membership at the Annual Meeting, held during the 2014 NARHC Fall Institute (Wed., Oct. 22) in Reno. 


Member RHCs who cannot attend the conference may cast their vote electronically (on or before Oct. 15th). A Survey Monkey email will be sent to the membership's primary contact person. One vote is allowed per member RHC. For a group membership (i.e. three affiliated RHCs), your vote will be multiplied by three. If your RHC has one or more persons attending the conference, please designate one to be the voter.  


The three candidates with the most votes will serve out three-year terms: Jan. 1, 2015-Dec. 31, 2017. Their biographies follow.  read more

Making a Difference...
(Names have been changed to protect patient privacy)  



A few months ago, baby Braden was failing to thrive. Not feeling well, Braden cried often, and couldn't keep anything down. His parents were exhausted and in serious need of help. Nothing they tried had worked. Braden's weight was down to the fifth percentile for his age when his mother took him to Jennifer Kozak, MD at the Tillamook Medical Group - Plaza, in Tillamook, Oregon. 


Dr. Kozak immediately recognized Braden's situation; Braden couldn't digest the proteins in dairy products. When he ate, his system reacted; leaving him constantly hungry and in physical distress. Dr. Kozak prescribed a special formula that works for him, but is expensive. Dr. Kozak's medical assistant worked with the family's insurance plan to get them to cover the formula. Now Braden's weight is in the 75th percentile for his age; he is healthy, happy, and growing right on schedule. Braden is now thriving!  read more   

Regulatory Burden



As I write, I see the RHC where I am employed, as a small and somewhat insignificant cog in the national healthcare arena.  In my home town, our little practice is a big fish in a very small pond, not unlike many of my rural cohorts around the country.  Isolated from those counterparts, our stories are all quite different.  What is not so dissimilar is the level of regulatory oversight, to which RHCs...even the little ones on swamps in Louisiana...are subjected.


As a leader, my role is to arm myself with knowledge about legislative and regulatory change of all sorts, including local and national reform  impacting not only RHC's, NP's/PA's, but also American medicine in general, either directly or peripherally. A daunting endeavor, my mind is often left swimming trying to guess what and how the change will affect our practice either now or in the future. Initially, I was hopeful about the positive potential of healthcare reform, but enduring the volume and rate change has come, my optimism sometimes wavers.


Most recently, fear hit home as I read of the plight of West Virginia RHC's caught up in a change in Medicaid payment methodology, based on a lawsuit filed by a non-RHC  group paid under a similar methodology.  read more 




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  • How can you recognize list serve emails? In the "To" line, instead of your name, it says "NARHC-news" or "Technical Assistance". read more 

The Next Technical Assistance Call... 

Billing for RHC and Non-RHC Services 

The next RHC TA call, "Billing for RHC and Non-RHC Services", is scheduled for September 18th at 3:00pm EASTERN. Our speaker will be a Janet Lytton. If you have any questions or subjects you would like Janet to try to cover during her presentation, please send them to and put "RHC TA Question" in the subject line.

call-in information for that call is:
Phone:             888-603-9640
Passcode:       9854323
Slide link:         Billing RHC and Non-RHC Services 

receive notifications about future TA calls, please sign up for the Technical Assistance Listserve on our website. Click here.   read more 

Early Experiences of RHCs in ACOs


To gain a better understanding of RHCs' participation in Accountable Care Organizations (ACOs), our research team recently conducted interviews with some of the physicians and administrative management of RHCs that joined ACOs in early 2012.  We explored their early experiences as ACO participants, including their motivations for joining and their opinions about the benefits of and deterrents to ACO participation.


Our interviewees were motivated by the ACO focus on community and population health, and the emphasis on prevention. They are hopeful that ACOs will provide higher quality care and greater patient choice. Some expressed uncertainty about whether the projected cost and quality benefits of ACO participation will be realized. In general, the ACO participants were cautiously optimistic and realize that achieving long-term benefits will take time.  read more


Physician On-Site Requirement Change


  • In July, CMS made several changes that affect Rural Health Clinics. One of those is regarding the previous requirement for a physician to be present in the RHC at least once every two weeks. CMS now recognizes that many of the physician's functions can be performed remotely by electronic means & has dropped "the every two week visit" from its requirements. This change became effective July 11, 2014. 
  • CMS estimates that the RHC's financial burden will be reduced because of this change. For all RHCs, CMS has estimated an annual savings of $26.4 million from fewer hours for on-site clinician visits. That total comes from their estimation that each RHC will save $6,649 x 3977. These numbers are from The Federal Register Vol 79, No 91, May 12, 2014, if you would like more detail. 
  • This change does not affect the existing requirement that a physician, PA or NP must be present at all times that the RHC operates. Most importantly this change does not affect the physician's responsibilities for oversight of that clinic, if an NP or PA runs/owns the clinic. read more
Tips for Coder-Physician Collaboration


The devil is in the details for effective coding, but the real answer to improving compliance & increasing revenues lies in communication and relationships. Although these areas are challenging to tackle, the benefits of doing so go far beyond improved compliance and revenues: they are essential elements in improving the total patient experience and are critical to demonstrating high-quality care at lower costs; in other words, the "triple aim." We've found the most significant improvements occur from:   

  • Breaking down the silos among the clinical/business staff & the front and back end of the revenue process;
  • Engaging physicians & soliciting their leadership throughout the process;
  • Educating the physicians, clinical support personnel, and coding staff about their respective roles and partnering with each other; and then,
  • Introducing the revenue integrity "conversation" into the day-to-day business of the practice.    read more

Telecom & Broadband Incentives Available



The Federal Rural Health Care Program provides up to $400 million annually to help healthcare providers like you gain affordable telecommunications and broadband services. Did you know only a quarter of the funding is committed each year?


A Free Webinar will be offered on Thursday, September 25 at 2:00PM-3:00PM EST to learn about Program benefits and how you can save up to 65% on your telecom and broadband costs.  C-Level Executives, IT Directors & Office Managers would benefit by attending. Here's what you will learn...  read more

Building a Successful RHC Team

FOOTBALL SEASON IS BACK! Last weekend, I watched When the Team Stands Tall, a movie based on the true story of the De La Salle High School winning team.  Although I am not the biggest football fan, I took away much more from the film than I ever imagined in terms of understanding the "soft" things which make or break a successful organization.  Often it is easy to gloss over the concepts of vision, mission, team-building and culture when we think about our practices. Isn't it obvious that we are committed to rural healthcare just by the virtue of our geographic location and our decision to become a RHC in the first place?  What else do we need?  read more

ICD-10 Deadline & Transitions   

"Road to 10" 


CMS has created "Road to 10,"an online resource, to help you jump start the transition to ICD-10. Built with the help of small practice physicians, "Road to 10" is a no-cost tool that will help you: 

  • Get an overview of ICD-10 by accessing the links on the the home pg.
  • Explore Specialty References by selecting a specialty below
  • Click the "Build Your Action Plan" box to create your personal action plan
Oct. 1, 2015, is the new compliance date for health care providers, health plans, &  health care clearinghouses to transition to ICD-10. HHS is also mandating continued use of ICD-9 through Sept. 30, 2015. By mandating use of ICD-9 through the end of Sept., 2015, individual payers cannot voluntarily seek to adopt ICD-10 prior to Oct. 1 as some had suggested. read more

Rural Health Coordinators  


Did you know that each CMS Regional Office staff includes a Rural Health Coordinator, who can provide technical, policy, and operational assistance on rural health issues?  Rural Health Coordinators are available if you have questions related to Medicare survey and certification, conditions of participation, payment, or other issues.  A list of the Regional Office Rural Health Coordinators is available at this link: read more 

Help Your Patients Save



US Pharmacy Card Plus provides its many members with access to thousands of discounted prescription medications and other healthcare services. Services include discounts on dental, vision, hearing, lab tests and imaging.


Free - NARHC Members may order as many cards as they like for use by their patients & staff. Card holders may be ordered so you can station them by your registration windows. Everyone is eligible (patients, staff, insured, underinsured). read more 

Webinars on the Health Care Law  

  • Got Coverage? Next Steps in Using Your Health Insurance
  • Special Enrollment Periods and Resources for the Uninsured

To participate in one of the webinars from the HHS Partnership Center, please select your topic from the list below and submit the necessary information. After registering you will receive an e-mail confirmation containing information about joining the webinar. All webinars are one hour.   read more

In This Issue
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NARHC Fall Institute
October 22-24, 2014
Atlantis Casino Resort Spa
Reno, Nevada
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