National Rural Health Association

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NRHA Regulatory Comment Letters

In addition to legislation, federal regulations can have a tremendous impact on the rural health care system. NRHA frequently comments on proposed regulations so that rural Americans have a voice in the regulatory process. Here you will find the latest comments submitted to federal agencies by NRHA, as well as important information from various federal agencies. For more information please contact NRHA's Government Affairs office at 202-639-0550.

2014 Inpatient Prospective Payment System Update

In June 2013, NRHA commented on the Centers for Medicare and Medicaid Services notice of proposed rulemaking for updating the IPPS for Federal Fiscal Year 2014.  Among other concerns, NRHA commented on the proposal in the rule to change the payment mechanisms for residents training at Critical Access Hospitals as well as payment calculations for Sole Community Hospitals.


Quality Improvement Organizations Request for Information

In May 2013, NRHA responded to a request for information (RFI) from the Centers for Medicare and Medicaid Services relating to possible changes to the Quality Improvement Organizations (QIO) program.  NRHA advocates maintaining state-based, rather than regional, QIOs.


Regulatory Burden Reduction

In April 2013, NRHA submitted comments to the Centers for Medicare and Medicaid Services on their proposed regulation to reduce regulatory burdens on rural providers. Among other comments, NRHA raised concern with the impending end to the enforcement moratorium for supervision requirements for outpatient therapy services and physician service orders at hospitals.


Meaningful Use Stage 2

In April 2012, NRHA submitted comments to the Office of the National Coordinator for HIT and the Centers for Medicare and Medicaid Services on their proposed regulation on standards for Meaningful Use Stage 2.  Included in our comments, NRHA raised concerns about attestation rates for Stage 1 and the pace for Stage 2 roll-out.  Additionally, NRHA commented on the burden placed on providers through the requirement for Computerized Physician Order Entry (CPOE) as "First Record of Order".


Accountable Care Organizations

In June 2011, NRHA submitted comments to the Centers for Medicare and Medicaid Services related to the proposed rule for the establishment of the statutorily mandated Medicare Shared Savings Program and Accountable Care Organizations (ACO). Mandated by the Affordable Care Act, ACOs are intended to produce significant savings for the Medicare program. An ACO is an integrated organization that endeavors to produce higher quality care through coordination and communication while reducing costs through the elimination of redundant procedures. Private ACOs have been around for 50 to 60 years and include big names such as Kaiser Permanente and Cleveland Clinic. While the ACO concept has garnered significant support, many organizations, associations and hospitals have been wary of the structure proposed in the current regulation. NRHA’s comment expressed concern with the beneficiary assignment calculation, “ACO professional” determination, anti-trust barriers, cost concerns, and a number of other issues.


CDC Community Transformation Grants

In May 2011 the Centers for Disease Control released its plan for distributing Community Transformation Grants. The money for these grants was mandated through the Affordable Care Act and included a provision that required a certain percent of the money be given to rural communities. NRHA’s comment expressed concern with the calculation of what is rural as well as the onerous application process.


Office of the National Coordinator 5-year Plan

In April 2011 the Office of the National Coordinator for Health IT (ONC) released a general plan for the developments and implementations it would like to see in the health IT field. NRHA is thankful to ONC for its leadership in this important arena and appreciates ONCs continued work on the development and implementation of health IT standards. The comment outlines suggestions that NRHA believes will strengthen the strategic plan in regards to rural implementation. NRHA supports the plan’s goals and looks forward to its continuing development. NRHA hopes that it continues to recognize the significant separation of large and small, rural and urban facilities in their ability to meet meaningful use standards.


Value Based Purchasing

In March 2011 the National Rural Health Association submitted comments to the Centers for Medicare and Medicaid Services related to the Value Based Purchasing program. In general, NRHA strongly supports the concept of aligning payment with the delivery of quality of care and supports the intent of the Affordable Care Act and the Hospital VBP proposed rule. Improved clinical quality for services delivered regardless of the size or location of hospitals should be the goal of all. To attain that laudable goal, equity for all facilities regardless of size or location is paramount. Comments include ideas and modifications that would make the program more rural friendly.

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