Medicare Compliance & Reimbursement

CMS seeks to flush out certified clinics not offering true "expanded access."

The Centers for Medicare & Medicaid Services is changing the rules for rural health clinics, which could have a big effect on clinics that were "grandfathered" into the RHC program in the early 1990s.
 
The grandfather clause originally protected a clinic's RHC status even if their service areas stopped being considered rural or medically underserved. The policy aimed to ensure that needed health care professionals would continue to be attracted to underserved rural areas. 
 
Unfortunately, it worked a little too well, as RHCs more than tripled between 1992 and 2001. Now the red flags are waving over the issue of clinics that might not have been certified if reviewed with current data.
 
Other provisions of the rule that could mean big changes for RHCs include:
  changes to the definition of a qualifying rural shortage area in which a Medicare RHC must be located;
  new criteria for identifying RHCs essential to the delivery of primary care services that can retain their status in areas no longer designated as underserved;
  limits to waivers of certain nonphysician practitioner requirements;
  payment limits on provider-based RHCs;
  a bar on the "commingling" of an RHC with another entity; and
  a mandate for RHCs to establish more robust quality assessment and performance improvement programs.
 
The final rule, published in the Dec 24, 2003 Federal Register, goes into effect Feb 23, 2004. To see the final rule, go to www.access.gpo.gov/su_docs/fedreg/a031224c.html
 
Lesson Learned: Benefits could be coming to an end for rural clinics in not-so-rural areas.