North American HMS

RHC FQHC Experts

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Proposed RHC Telehealth Legislation

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Due to COVID, we have seen how out-of-date telehealth regulations had been. It is essential the legislative changes be made to expand Telehealth statutes for Rural Health Clinics and FQHCs. As soon as the Public Health Emergency ends, Telehealth services and reimbursement will go back to the “old normal”.  We will no longer be able to provide services as the distant site. 

Please contact your US Senators and US Representatives.  Advocate for change!

H.R. 6792/S. 3998 – Improving Telehealth for Underserved Communities Act of 2020

  • allows RHCs/FQHCs to bill for telehealth through their normal reimbursement mechanisms for the duration of the Public Health Emergency.
  • raises the RHC cap to $92.03

Link To Senate Bill 3998

Link to HR 6792

H.R. 7187 – HEALTH Act of 2020

  • Permanently establishes RHCs/FQHCs as distant site providers paid through normal mechanisms (telehealth services would also count as visits)
  • Makes the payment methodology explicit.
  • Eliminates originating site requirements for telehealth services furnished by RHCs/FQHCS

HHS Medicaid-CHIP Provider Distribution!

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HHS is distributing $15 billion to eligible Medicaid/CHIP providers. Each provider will receive at least 2 percent of reported gross revenue from patient care. The final amount will be determined from data submitted to HHS.

Before applying through the enhanced provider relief portal, applicants should:

Read the Medicaid Provider Distribution Instructions – PDF*

Download the Medicaid Provider Distribution Application Form – PDF*

If the facility did not get money from the targeted RHC relief payment, we highly recommend this route. Multiple CCN numbers can be reported. Please see here for Provider Relief Fund information:

Provider Relief Fund Information

Please give us a call at 314.968.0076 extension 201 to request more information or email us at info@northamericanhms.com.

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RHC Emergency Medication Requirement 2019

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Emergency Medication Requirement Change: QSO-19-18-RHC

CMS has allowed RHCs to determine which Emergency Meds are appropriate for the RHC.  These are stated in 42 CFR 491.9(c)(3).  This includes the following: “analgesics, anesthetics (local),antibiotics, anticonvulsants, antidotes and emetics, serums and toxoids.”  This is an extremely dated medication list – think 1977.  Most of us do not know what serums and toxoids are?

I have NEVER been to an RHC that had used, or were glad they had, an anticonvulsant.  It is stocked for the survey.  It never is used.  The medication expires.  It gets replaced, to never be used again.

There was a recent controversy over whether RHCs must stock snake venom antidote.  Even if there was not a specific risk in the RHC’s geographic area of snake bite.  Now we have the answer. We do NOT have to store snake venom antidote.

On September 3, 2019, the Centers for Medicare and Medicaid Services (CMS) released  “Revised Rural Health Clinic (RHC) Guidance Updating Emergency Medicine Availability—State Operations Manual (SOM) Appendix G- Advanced Copy.

Summary:  The Centers for Medicare & Medicaid Services (CMS) is updating the medical emergency guidance as it pertains to the availability of drugs and biologicals commonly used in life saving procedures.

Your Emergency Medication policy should be re-written to include consideration of each of the medication groups listed in 491.9(c)(3).  After considering each of these, state which medications will be stored.  It should also be documented who made the final decision.  This would preferably be the RHC Medical Director and/or NP/PA.

The updated text says:

“…when determining which drugs and biologicals to have available in order to provide medical emergency procedures as a first response to common life-threatening injuries and acute illness es, an RHC must consider each of the categories listed in regulation.

While each category of drugs and biologicals must be considered, all are not required to be stored. An RHC must have those drugs and biologicals that are necessary to provide its medical emergency procedures to common life-threatening injuries and acute illnesses.

In making this determination, the RHC should consider, among other things, accepted medical standards of practice, community history and the medical history of its patients.

The RHC should have written policies and procedures for determining what drug/biologicals are stored to provide such emergency services. The policy and procedures should also reflect the process for determining which drugs/biologicals to store, including who is responsible for making this determination.

They should be able to provide a complete list of which drugs/biologicals are stored and in what quantities. Since RHCs and federally qualified health centers (FQHCs) share the same regulatory requirements as it relates to emergency procedures under 42 CFR 491.9(c)(3), this revision will also apply to FQHCs.

Effective Date: Immediately.
This guidance should be communicated with all survey and certification staff, their managers and the State/Regional Office training coordinators within 30days of this memorandum.
Please let us know if you need help with your policies!

RHC Emergency Preparedness Rule

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RHC providers have new requirements!  CMS issued new Emergency Preparedness Rules which apply to all 17 provider types. As a result, Rural Health Clinic (RHC) providers need some upgrade! Please see my accompanying presentation which summarizes the CMS Rule.  The rule text was my sole source of information and text.

RHC Emergency Preparedness Presentation

Rule Change Background

On September 8, 2016 the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. The regulation goes into effect on November 16, 2016. Health care providers and suppliers affected by this rule must comply and implement all regulations one year after the effective date, on November 16, 2017.

Purpose: To establish national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters, and coordination with federal, state, tribal, regional and local emergency preparedness systems. The following information will apply upon publication of the final rule:

  • Requirements will apply to all 17 provider and supplier types.
  • Each provider and supplier will have its own set of Emergency Preparedness regulations incorporated into its set of conditions or requirements for certification.
  • Must be in compliance with Emergency Preparedness regulations to participate in the Medicare or Medicaid program. The below downloadable sections will provide additional information, such as the background and overview of the final rule and related resources.

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