CHA News Article

Rural Health Clinic Location Determination Guidance Updated

According to a recent memo from the Centers for Medicare & Medicaid Services (CMS), CMS regional office survey and certification staff are responsible for making applicant eligibility determinations for rural health clinic (RHC) location and shortage area criteria. The memo, attached, notes that although state survey agencies make preliminary assessments of eligibility when planning survey schedules, the authority to make a determination may not be delegated to the state survey agency or other non-CMS entities.

CMS also notes that regional offices must not provide advance determination on location eligibility, even as “preliminary,” to any initial applicant seeking to enroll in Medicare as an RHC, or to any existing RHC considering relocating. RHCs that relocate are required to submit form CMS-855A updating their location information with the appropriate Medicare administrative contractor within 90 days of their relocation.