Regulatory Affairs Updates Archive

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2006 and Earlier Regulations

CMS Releases Ruling on Rural Health Clinics

On Friday, September 22, 2006, CMS released an interim final rule for Rural Health Clinics. The interim final rule formally withdraws the RHC rule changes announced on December 24, 2003. Those rule changes were suspended in early 2004 because they exceeded the time limit for publication of final rules, as established by the Medicare Modernization Act of 2003.

In effect, this regulatory action simply strikes from the books regulations that have not been implemented (with the exception of changes that are self-enforcing by law or have been previously adopted through a CMS program memorandum.) CMS intends to reissue new proposed RHC rules in the spring of 2007.

While this interim final rule is merely procedural in anticipation of a proposed rule due sometime in 2007, NRHA is taking this opportunity to provide comments that will inform CMS’s drafting of the new proposed rule.

Read NRHA’s comments on the interim final rule. [Here]

The Federal Register notice for the Interim Final Rule can be found [Here]

Coalition on Healthcare Financing Comments on HUD Proposal

As part of the Coalition on Healthcare Financing, NRHA recently submitted
comments to the Department of Housing and Urban Development (HUD) on the Department's proposed increase to its multifamily and healthcare mortgage insurance premiums.
Read the Coalition for Healthcare Financing's comments.

House and Senate Send Letters to CMS Calling for Delay of Proposed Changes to Hospital Payments

The House and Senate sent identical letters to CMS Administrator Mark McClellan last week calling for a delay in implementation of the proposed changes to the inpatient hospital prospective payment system until fiscal year 2008. The letters expressed concern about the effect on rural hospitals and supported the concept of basing DRG weights on costs rather than charges. The effort was lead by Senators Santorum (R-PA) and Conrad (D-ND) and Representatives English (R-PA) and Pomeroy (D-ND). The final letters were signed by 53 Senators and 189 Representatives. The letters can be found on the NRHA website at:

House IPPS Letter

Senate IPPS Letter

Read CMS Administrator McClellan's response

CMS Regulations on CAH Relocation

In November, 2005, CMS issued overly prescriptive guidelines governing when a Critical Access Hospital can rebuild or relocate. These guidelines went well beyond the requirements set forth in regulation and present barriers that make it very difficult to rebuild or relocate a critical access hospital.

Read a letter from the House of Representatives criticizing the CAH relocation guidelines.

Read letter from U.S. Senators criticizing the CAH relocation guidelines.

NRHA Comments to CMS on the Proposed Regulatory Changes to the Medicare Inpatient Hospital Prospective Payment System for Fiscal Year 2007

The Centers for Medicare and Medicaid Services published the proposed regulation for the Medicare inpatient prospective payment system for fiscal year 2007 on April 25, 2006. The proposed regulation contains the most significant changes to the system since its inception in 1983. NRHA submitted its comments on June 7, 2006.

In short, the system re-weights the diagnosis related groups (DRGs) to better reflect costs, rather than charges. In general, this is a good change for rural hospitals, although there is great variation between hospitals and there are some technical concerns with the methodology that need to be addressed. However, these gains are more than outweighed by losses that rural hospitals will see from CMS’s proposal to adjust DRGs by severity, which CMS proposes to implement in fiscal year 2008, or sooner. The combination of the two proposals will result in a cut to rural PPS hospitals of 1.3 percent. NRHA’s comments reflect our strong support for the concept of DRG re-weighting based on costs and our grave concerns with the severity adjustment piece of the proposal. In addition, NRHA took this opportunity to again voice our concerns with CMS’s overly burdensome interpretive guidelines governing the relocation of Critical Access Hospitals.

Read NRHA’s Comments.

Medicare Guide to Rural Health Services Information For Providers, Suppliers and Physicians Now Available Through CMS

The Medicare Guide to Rural Health Services Information offers Medicare providers, suppliers, and physicians rural health information and resources in a single source. (8MB Download)

http://www.cms.hhs.gov/medlearn/MedRuralGuide.pdf

NRHA Comments to CMS on the Outpatient Prospective Payment System Changes Proposed for 2006.

Read NRHA's comments to CMS regarding the Medicare Program; Proposed Changes to the Hospital Outpatient Prospective Payment System and Calendar Year 2006 Payment Rates, CMS–1501–P, 70 Fed. Reg. 42,674 et seq. (July 25, 2005). [Click Here]