From the CMS, Through the Community Health Access and Rural Transformation (CHART) Model, CMS aims to continue addressing disparities by providing a way for rural communities to transform their health care delivery systems by leveraging innovative financial arrangements as well as operational and regulatory flexibilities.

The approximately 57 million Americans living in rural communities, including millions of Medicare and Medicaid beneficiaries, face unique challenges when seeking healthcare services, such as limited transportation options, shortages of health care services, and an inability to fully benefit from technological and care-delivery innovations. These challenges result in rural Americans facing worse health outcomes and higher rates of preventable diseases than those living in urban areas.

Community Transformation Track

CMS will select up to 15 Lead Organizations for this track. A Lead Organization is a single entity that represents a rural Community, comprised of either (a) a single county or census tract or (b) a set of contiguous or non-contiguous counties or census tracts. Each county or census tract must be classified as rural, as defined by the Federal Office of Rural Health Policy’s list of eligible counties and census tracts used for its grant programs.1 Examples of entities eligible to serve as Lead Organizations include, but are not limited to, state Medicaid agencies, State Offices of Rural Health, local public health departments, Independent Practice Associations, and Academic Medical Centers.

Lead Organizations will be responsible for working closely with key model participants (e.g., including Participant Hospitals and the state Medicaid agency) and driving health care delivery system redesign by leading the development and implementation of Transformation Plans with their community partners. The Transformation Plan is a detailed description that outlines the community’s plan to implement health care delivery redesign strategy.

Lead Organizations and their community partners will receive upfront cooperative agreement funding, financial flexibilities through a predictable capitated payment amount (CPA) for Participant Hospitals in a community, and operational and regulatory flexibilities.

The 15 Community Lead Organizations are critical to the success of the Model because they will coordinate efforts across the community to ensure that access to care is maintained and that the needs of various stakeholders are understood and accounted for in the transformation plan. Lead Organizations are responsible for managing cooperative agreement funding, recruiting Participant Hospitals, engaging the state Medicaid agency, establishing relationships with other aligned payers, convening the Advisory Council, and ensuring compliance with Model requirements. Ultimately, the Lead Organization will oversee the execution and coordination of a Transformation Plan that outlines the health care delivery redesign strategy for the Community.

CO Transformation Track

CMS will select up to 20 rural-focused ACOs to receive advanced payments as part of joining the Medicare Shared Savings Program (Shared Savings Program). Building on the success of the ACO Investment Model (AIM), the advanced shared savings payments are expected to help CHART ACOs engage in value-based payment efforts that will improve outcomes and quality of care for rural beneficiaries.  A majority of ACO providers/suppliers of the CHART ACO must be located within rural counties or census tracts as defined by FORHP.

CMS will offer CHART ACOs advanced shared savings payments comprised of two components:

• A CHART ACO will be able to receive a one-time upfront payment equal to a minimum of $200,000 plus $36 per beneficiary to participate in the 5-year agreement period in the Shared Savings Program.
• A CHART ACO will be able to receive a prospective per beneficiary per month (PBPM) payment equal to a minimum of $8 for up to 24 months.

The amount for the upfront payment and the PBPM will vary based on the level of risk that the CHART ACO accepts in the Shared Savings Program and the number of rural beneficiaries assigned to it based on the Shared Savings Program assignment methodology, up to a maximum of 10,000 beneficiaries.

The CHART ACO will enter into participation agreements with CMS to participate in both the Shared Savings Program and the CHART Model and, for the full duration of the agreement period, meet the requirement that a majority of its ACO providers and suppliers are located within rural counties or census tracts.

Timeline

CMS anticipates the Notice of Funding Opportunity (NOFO) for the Community Transformation Track will be available in September on the Model website. The Request for Application (RFA) for the ACO Transformation Track will be available in early 2021.

The forthcoming NOFO and RFA will contain detailed information to assist interested applicants.

Additional Information

• Fact Sheet
• Press Release
• Webinar: Community Health Access and Rural Transformation (CHART) Model – Overview

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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

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Contact US Congresspeople and Senators to support “The Health Act”!

On Thursday, June 18th, the Improving Telehealth for Underserved Communities Act was introduced in the Senate by Sen. Cindy Hyde-Smith (R-MS) and Sen. Angus King (I-ME).

Please support the Health Act. 

• RHCs and FQHCs bill telehealth visits through their normal reimbursement mechanisms throughout the COVID-19 public health emergency.
• Costs associated with telehealth are incorporated into annual cost reporting.
• Telehealth visits count toward RHC productivity standards.
• Claims data is accurate because accurate coding would be used, rather than the single G2025 code.
• No recoupment period in July.
• See One Page summary here:  Health Act One Page Summary.

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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.

Please follow us on Facebook and Twitter!

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The post HHS Medicaid-CHIP Provider Distribution! first appeared on North American Healthcare Management Services.

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.

The post RHC Emergency Medication Requirement 2019 first appeared on North American Healthcare Management Services.

Here is the updated Advanced RHC Billing presentation that I gave at NARHC this week.  I updated claim examples and added some explanation on service detail billing.  I thought my comments on billing full charge amounts vs using the “$.01” method needed a bit more clarification.  Let me know if you have any questions –

Charles

Advanced RHC Billing v.2019 Updated

The post Advanced RHC BIlling Presentation: NARHC Fall 2019 St. Louis first appeared on North American Healthcare Management Services.

Document Number:  2019-20736 “Medicare and Medicaid Programs: Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction; Fire Safety Requirements for Certain Dialysis Facilities; Hospital and Critical Access Hospital Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. ”

The new final rule does the following:

• changes the Policy Review and Annual Evaluations to biennial requirements.
• changes the requirement for facilities to review their emergency preparedness program to at least biennial.
• eliminates the need to document outreach efforts to local emergency resources, but facilities will “still be required to include a process for cooperation and collaboration” with them.
• requires facilities to provide training biennially or every 2 years, after facilities conduct initial training on their emergency program.
• requires that providers of outpatient services conduct only one testing exercise per year, that either a community-based full-scale exercise (if available) or conduct an individual facility-based functional exercise every other year.
• In the opposite years, these providers may conduct the testing exercise of their choice, which may include either a community-based full-scale exercise (if available), an individual, facility-based functional exercise, a drill, or a tabletop exercise or workshop that includes a group discussion led by a facilitator.
• if a provider experiences an actual natural or man-made emergency that requires activation of their emergency plan, inpatient and outpatient providers will be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event.

https://www.federalregister.gov/documents/2019/09/30/2019-20736/medicare-and-medicaid-programs-regulatory-provisions-to-promote-program-efficiency-transparency-and

The following are now biennial, not annual requirements:

Review of Patient Care Policies §491.9(b)(4)

RHC and FQHC Program Evaluation – §491.11(a)

Annual Review of Emergency Preparedness Program – §491.12

Annual Emergency Preparedness Training Program §491.12(d)(1)(ii)

The requirements for the following have been eased:

Documentation of Cooperation Efforts – §491.12(a)(4) has been eliminated

Annual Emergency Preparedness Testing – §491.12(d)(2) – only one required per year

Let us know if you have any questions!

Charles

The post New RHC Final Rule – Patient Policies, Program Evaluation and Emergency Preparation first appeared on North American Healthcare Management Services.

https://www.washingtonpost.com/news/national/wp/2019/05/11/feature/whos-going-to-take-care-of-these-people/?utm_term=.667991f96042

The post “Healthcare deserts” are being created in Rural America. first appeared on North American Healthcare Management Services.

This is an example of the Medicare RHC Negative payment when the whole charge and deductible amount exceeds the RHC encounter rate.  Medicare Negative Payments Example

The correct way to get these posted to your patient accounts?  However you can get it to balance!!

Have fun!

Charles

The post Medicare RHC Negative Payment first appeared on North American Healthcare Management Services.

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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