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 

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 

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 

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

HEALING BABY BRADEN 

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

AND THE POWER OF NARHC 

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 

Listserve:  

LISTSERVE BASICS

• No advertising or self promotion is allowed.
• Any member of List Serve may post a question, anyone may answer. Our administration monitors & jumps in if we see wrong answers.
• Do not ask for or share your charges for services rendered or wage rates. This could be construed as "price fixing".
• 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 

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

FURTHER EXPLAINED (42 CRF Part 491) 

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

FROM THE FEDERAL RURAL HEALTH CARE PROGRAM 

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?

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

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