With millions of rural Americans at risk of losing health insurance and direct access to care, an unprecedented number of National Rural Health Association (NRHA) members will descend upon Washington, D.C. today to advocate for preserving healthcare access and delivery of services.
Among those attending the NRHA Policy Institute and Capitol Hill meetings will be rural healthcare leaders from across the nation advocating for the provision of regulatory relief for 62+ million rural residents. Other agenda items will include the impact of future changes to the Patient Protection and Affordable Care Act (PPACA), the need for the 340B Drug Program, the opioid and substance abuse public health epidemic, and the need for expanded telehealth reimbursements.
To drive home what’s at risk, attendees will thread impact stories with the following simple facts: 80 critical access hospitals have closed since 2010, with 673 more currently being at risk of closure; there will be a primary care shortage of 30,000 by 2025; and approximately one million nurses are expected to retire in the next 10 years.
Advocates are also expected to tell their respective congressional delegations that rural health is seeking regulatory relief, recognizing several key areas that have gone unaddressed, including the following:
- Critical Access Hospitals (CAHs) and several Sole Community Hospitals (SCHs) should have “eligibility” for Indirect GME (IME).
- Hospital Star Ratings treat rural hospitals unfairly, and rural relevant measurements are needed.
- More equitable Merit-Based Incentive Payment System (MIPS) performance comparisons should be made to those of equivalent cohorts in the program, creating more of an apple-to-apple framework and offering a more level playing field for incentives.
- The “Section 603 Site-Neutral” payment for new off-campus provider-based departments (PBD) harms rural providers.
- A common-sense approach is needed for the “exclusive use” standard.
- The elimination of the longstanding troublesome issue of the “96-hour condition of payment” requirement would reduce all of the unnecessary red tape, aligning with the congressional intent of designating CAHs.
- The improper Medicare Administrative Contractor (MAC) denial of the low-volume hospital adjustment must be addressed.
- Changing the supervision requirements for outpatient therapy services to general supervision from direct supervision would protect patient safety and access.
All of these aforementioned issues are widening the disparities in service between rural and non-rural providers.
One factor that would help enormously and would in essence act as a tourniquet limiting the bleeding of rural healthcare is “Save Rural Hospitals,” a piece of legislation known as HR3225 that was introduced by Rep. Sam Graves from the 6th Congressional District in Missouri. First introduced on July 27, 2015 and with support of 34 other members, it was enacted during the 114th Congress when its session ended on Jan. 3, 2017. Known as a “rural provider payment stabilization” effort, the bill included several high-impact provisions, including but not limited to the following. It will:
- Provide extension of Medicaid primary care payments
- Eliminate Medicare and Medicaid DSH payment reductions
- Eliminate Medicare sequestration for rural hospitals
- Provide reversal of all “bad debt” reimbursement cuts
- Provide permanent extension of the rural ambulance and super-rural ambulance payment
- Provide permanent extension of current low-volume and Medicare-dependent hospital payment levels
- Provide establishment of Meaningful Use support payments for rural facilities struggling (recognizing value-based focus)
- Reinstate sole community hospital “hold harmless” payments
- Provide rural Medicare beneficiary equity by eliminating higher out-of-pocket charges for rural patients.
This also includes an innovative model of care for the future called the Community Outpatient Model. This new Medicare payment designation ensures emergency access for rural patients. This model also allows flexibility through outpatient care established by a Community Needs Assessment (ironically embedded within the PPACA). Additionally, primary care would be provided through a Federally Qualified Health Center (FQHC) lookalike model or a Rural Health Clinic (RHC). There would be no preclusion to swing beds, observation beds, population health models of care, telehealth services, home health services, or infusion services. The Medicare reimbursement ratio for the model is 105 percent of reasonable cost. To help implement it, there would be $50 million in wraparound population health grants.
Rural healthcare needs congressional (and CMS) support in stabilization and reconfiguration. They are vital and deserve vitality.