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RHC Payment Increase and Sequestration Delay

Beginning on April 1st, the Rural Health Clinic (RHC) per visit upper payment limit increased from $87.52 to $100. The increased upper payment limit is a direct result of the payment changes included in Section 130 of the Consolidated Appropriations Act of 2021. Some Medicare Administrative Contractors have already sent out letters to RHCs informing them of the increased upper limit and how it will affect their All-Inclusive Rate payments.

Meanwhile, on Capitol Hill, the House is expected to pass legislation after they return from recess (April 12th) that includes a grandfathering fix for RHCs and delays the resumption of a 2% Medicare sequestration cut until the end of 2021 that affects all providers.  The likely vehicle to do this is H.R> 1868.

While H.R. 1868 is not yet law, the expectation that this bill will pass is so strong that CMS announced that they will temporarily hold claims with dates of service on or after April 1, 2021, pending Congressional Action. This includes RHC claims that would have otherwise been subject to the 2% sequester reduction.

For context, when COVID-19 began last year, Congress temporarily waived the standing 2% across-the-board reduction in Medicare reimbursement (the sequester) until the end of 2020, and then later through March 31, 2021. H.R. 1868 will now extend this waiver through the end of 2021.

Specifically, section 2 of the Senate-passed version of H.R. 1868 contains the RHC grandfathering fix which will:

– Fix the grandfathering date for under 50-bed hospital RHCs from December 31, 2019, to December 31, 2020;

– Allow under 50-bed hospital entities that submitted applications to become an RHC by December 31, 2020, to be grandfathered-in; and

– Establish a methodology for setting the upper payment limits for grandfathered RHCs that did not have reimbursement in 2020.

USDA investing over $3M to improve distance learning and telemedicine in Alabama

The United States Department of Agriculture (USDA) announced an investment of over $3 million in rural Alabama on Tuesday.

Five Alabama projects related to telemedicine or distance learning will receive a share of the investment, which was publicized by the Department’s Office of Rural Development in Montgomery.

“USDA is helping rural America build back better using technology as a cornerstone to create more equitable communities. With health care and education increasingly moving to online platforms, the time is now to make historic investments in rural America to improve quality of life for decades to come,” said Agriculture Secretary Tom Vilsack in a release.

Vilsack, once a governor of  Iowa, was President Barack Obama’s Agriculture secretary from 2009-2017. He was confirmed this week to that same position under President Joe Biden. Both of Alabama’s U.S. Senators supported Vilsack’s confirmation.

All projects being funded in Thursday’s announcement are a part of the Agriculture Department’s Distance Learning & Telemedicine Grants program. The organization requesting the grant had to provide a 15% match.

USDA Rural Development provided a summary of each of the projects in Alabama:

In west Alabama, USDA’s investment of $916,948 will be used by the University of Alabama to connect 23 ambulances to seven hospitals in eight different rural counties in west-central Alabama. This network of ambulances will be equipped with telemedicine services to relay patient data to emergency room physicians. This technology will allow emergency room physicians to interact with emergency medical technicians, which will help to provide more efficient care for patients.

In Lauderdale County, USDA’s investment of $245,618 will be used by the Lauderdale County Board of Education to install distance learning systems in Lauderdale County’s elementary and secondary schools, as well as at the Board of Education’s offices. The Board will purchase mobile carts, bridging software and wireless access points to create a remote teaching system. The distance learning system will enable teachers to provide lessons and educational opportunities to more students.

In Clarke, Marengo, Wilcox and Monroe counties, USDA’s investment of $744,150 will be used by Physicians Care of Clarke to create a telehealth system across several regional healthcare systems. Leveraging primary health care sites, school-based health care sites, and administrative sites, rural residents in the region will now have access to primary and specialist physicians. This project will help install telemedicine carts and videoconferencing equipment at each clinic to capture diagnostic information, provide clinical supervision, and consultation services. This will help rural residents who are geographically isolated and have difficulty accessing serving primary and specialty care providers.

In Bibb, Dallas, and Talladega counties, USDA’s investment of $580,308 will be used by the University of Montevallo to establish a telemedicine system to provide access to mental health through its Community Counseling Clinic. Telemedicine end-user units will be installed in high schools in Bibb, Dallas and Talladega counties that will be used to offer telemental health services to students, teachers and community members. The University will also use distance learning equipment to offer distance education for professional educators and instructional leaders, as well as high school students in dual-enrollment courses.

In Bibb, Perry, Chilton, and Jefferson counties, USDA’s investment of $789,150 will be used by the Cahaba Medical Care Foundation for teleconferencing equipment, to offer distance learning for its family medicine residents. This program helps medical school graduates achieve medical licensure or board certification, while applying their skills in rural areas. In addition to educational uses, the equipment will also be used to provide telemedicine services in response to the influx of patients due to the COVID-19 pandemic.

Click here to view the news story.

RURAL HEALTH CLINIC CHANGES INCLUDED IN FINAL COVID BILL

During the final negotiations of the COVID relief package from late December, 2020, Sen. Chuck Grassley (Iowa) led efforts to include modified language from the Rural Health Clinic Modernization Act. This language was included in the final bill, which does the following:

  • Raises the Independent RHC cap to $100 on April 1, 2021, and set to rise each year thereafter to $190 by 2028.
  • Newly established RHCs would now also be subject to the increased cap, which means that no new RHCs (even those purchased or established by hospitals with less than 50 beds) could receive uncapped cost-based reimbursement.
  • Uncapped RHCs in existence today would be grandfathered-in at their current All-Inclusive Rate and would still see year-over-year increases but would be constrained to their current AIR plus an adjustment for MEI (the Medicare Economic Index).
  • RHCs will now be allowed to bill for hospice attending physician services.

Although this is great news for independent RHCs, this may come at the cost of our provider-based RHCs. It does not appear that any clinics will have a reduction in their all-inclusive rate, which is a very important positive factor. But, this new language will prevent hospitals from establishing new RHCs and receiving the more lucrative uncapped AIR. Again, it’s important to note that this will not affect the AIR that any provider-based clinics are currently receiving…they are grandfathered-in to this new policy.

The board and legislative committee of the Alabama Rural Health Association will examine this language more closely and determine its effects to Alabama clinics. Stay tuned for more information.

HRSA E-mail to RHCs for COVID Reporting

We have received word that RHCs throughout Alabama recently received this notification from HRSA via e-mail. This is a follow-up to the requested attestation for funding received by RHCs from the CARES Act. Please be sure to comply with the reporting requirements in order to not jeopardize the funding that you received earlier this year in support of COVID response.


Dear Rural Health Clinic Administrators and Managers,

You are receiving this email because the Federal Office of Rural Health Policy (FORHP) within the Health Resources and Services Administration (HRSA), recently compiled an email list (RHC-COVID-19-TESTING-PROGRAM) of Rural Health Clinic (RHC) administrators and managers in order to better communicate Rural Health Clinic COVID-19 Testing Program information and updates.

The Paycheck Protection Program and Health Care Enhancement Act authorized the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), to provide $225 million to RHCs for COVID-19 testing and related expenses. Beginning May 20, 2020, HRSA issued funding as one-time payments to RHC organizations of $49,461.42.

The terms and conditions for this program specify that, “The Recipient shall submit reports as the Secretary determines are needed to ensure compliance with conditions that are imposed on this Payment, and such reports shall be in such form, with such content, as specified by the Secretary in future program instructions directed to all Recipients.”  

To monitor and assess the program, HRSA has established a set of proposed measures that funded RHCs report back to HRSA at the Tax Identification Number (TIN) level. This brief set of proposed measures includes basic information on the RHC organization, the number of and location of testing sites (active and inactive), information on the use of funds, the total number tests conducted, and the number of COVID-19 positive tests. 

HRSA proposes to use this information to evaluate the effectiveness of the program at an aggregate level. As proposed, funded organizations must report the number of tests conducted and the number of positive tests on a monthly basis for the duration of the reporting period retroactively to May 2020. No personally identifiable, patient-level information is being requested.  

HRSA will be in contact with RHCs in the coming weeks with more information on the RHC COVID-19 Testing Reporting (RHC CTR) website, upcoming webinar, and other additional information. Please forward the email to the best contact for your RHCs COVID-19 Testing Program and cc: RHCCOVID-19Testing@hrsa.gov if you are the incorrect recipient. HRSA has funded the National Association of Rural Health Clinics to provide technical assistance to RHCs on the RHC COVID-19 Testing Program. If you have additional questions you may emailRHCcovidreporting@narhc.org.   

Trump Administration Announces Details of New Rural Health Model

The Centers for Medicare and Medicaid Services (CMS) recently unveiled the details of the Trump Administration’s long-awaited, new rural health payment model, the Community Health and Rural Transformation (CHART) Model. The CHART Model aims to, “[Unleash] innovation through new funding opportunities that will increase access and improve quality,” by allowing a limited number of rural health providers to participate in one of two tracks, the Community Transformation Track and the Accountable Care Organization (ACO) Transformation Track. According to CMS, this new model comes as a response to President Trump’s Executive Order on Improving Rural Health and Telehealth Access that was made on August 3rd, as well as the President’s Medicare Executive Order and CMS’s Rethinking Rural Initiative.

The Community Transformation Track will include up to 15 lead organizations. These lead organizations are entities representing a rural communities comprised of either a single county or a set of contiguous or non-contiguous counties. This track will create a $75 million grant program for the 15 organizations to share. This experimental track aims to give these up-front dollars to providers and allow them greater flexibility to create their own health care programs with a patient focus. 

The ACO Transformation Track builds on the successes the very popular and successful ACO Investment Model (AIM) program. In this model, CMS will select 20 rural-focused ACOs to receive advanced payments to engage in value-based payment efforts aimed at improving outcomes and quality of care for rural beneficiaries. We are supportive of this new and exciting opportunity, but we also want to acknowledge that how CMS currently sets spending benchmarks disadvantages certain rural providers. Currently, CMS compares the per-patient costs of a region’s ACO with the operating expenses of its non-ACO competitors, but rural ACOs are often the only significant provider in their region. Thus, rural ACOs often face a much lower spending benchmark, because urban and suburban regions often have more non-ACO providers. We are calling upon CMS to fix this ‘rural glitch’ within the MSSP. This is a critical and common-sense step towards establishing greater payment for rural providers that are providing high quality care to their communities while decreasing health care spending. Unlike the earlier AIM program, participants in the ACO Transformation Track will enter into two-sided risk arrangements as part of the Medicare Shared Savings Program (MSSP), which could be a barrier to entry for many rural hospitals unwilling to bear risk without being able to define that risk completely. Additionally, a CHART ACO is limited to 10,000 covered lives which could increase actuarial volatility in participating in a dual-sided risk program.

The timeline indicates that a Notice of Funding Opportunity (NOFO) for the Community Transformation Track will be available in September on the Model Website and the Request for Application (RFA) for the ACO Transformation Track will be available in early 2021.