Critical Access Hospitals (CAHs) are hospitals with a maximum of 25 beds that are located in a rural area over 35 miles from another hospital. A rural hospital that is 15 miles from another hospital in mountainous terrain (or areas with only secondary roads) may also qualify as a CAH. There are 28 such hospitals in California. CHA advocates for their interests on federal and state legislative and regulatory policies.
The Centers for Medicare & Medicaid Services (CMS) will hold its third special open door forum (ODF) regarding the new inpatient admission and medical review criteria commonly referred to as the two-midnight rule Tuesday, Nov. 12 from 10 a.m. – 11 a.m. (PT). This call will give hospitals an important opportunity to ask CMS questions about the finalized policy and recently released subregulatory guidance from Nov. 5. To participate, call (866) 501-5502 and enter Conference ID # 98515298.
CHA urges Critical Access Hospitals to also participate in CMS’ special ODF on Wednesday, Nov. 13 from 11 a.m. – noon (PT). Special attention will be paid to clarifying the condition of payment related to the 96-hour rule as well as the related condition of participation. To participate, call (800) 837-1935 and use conference ID # 70964241.
The Centers for Medicare & Medicaid Services (CMS) has posted the attached transcript from its Sept. 26 special open door forum (ODF) regarding the new inpatient admission and medical review criteria commonly referred to as the two-midnight rule. On the call, CMS read frequently asked questions and attempted to clarify a number of questions unaddressed in recent guidance, including the 96-hour rule for critical access hospitals (CAH). CMS has announced a rural health ODF for Wednesday, Nov. 13 from 11 a.m. – noon (PT) that will further clarify guidance on the CAH 96-hour rule. The ODF agenda also includes discussion on rural health clinic contracting policies proposed in the federally qualified health center prospective payment system proposed rule. To participate, dial (800) 837-1935 and reference conference ID 70964241.
Last week, the Department of Health and Human Services’ Office of the Inspector General (OIG) released a report recommending that qualifications of the nation’s critical access hospitals (CAHs) be reviewed and reassessed, with potential to generate substantial Medicare savings by removing certifications for those CAHs that no longer qualify. The OIG recommended that the Centers for Medicare & Medicaid Services (CMS) seek legislative authority from Congress specifically to revise CAH conditions of participation and remove the permanent exemption from the current distance requirement. The report, which examined CAH locations using digital maps to determine their eligibility, states that many current CAHs would no longer qualify for the program under the distance requirement. While the American Hospital Association estimates the recommendations could negatively impact as many as 75 percent of CAHs nationwide, most California CAHs would not be affected because they would continue to meet distance and location requirements.
The OIG’s report is attached. CHA will continue to update members on this issue as it develops.