Regulatory Comment Letters
Regulations are used by the administration to implement a piece of legislation appropriately or to gradually implement policy to changing situations. By law, whenever regulations are implemented there must be an opportunity for the public to respond to the proposed change.
The NRHA monitors these regulatory changes and informs our members through our educational conferences, eNews, the annual Legislative and Regulatory Agenda and on our web site. In addition, whenever a regulatory change proposal will have a large impact on rural America, we will submit a comment letter on behalf of the membership. We list our final comment letters below in chronological order.
2008
RHC and FQHC Changes in Conditions of Participation Proposed Rule
CMS had released the proposed rule on June 27 for the stated purpose to update the RHC program, especially the statutory requirements created by Congress in the Balanced Budget Act of 1997. These statutory requirements centered on the location of RHCs and would make all RHCs re-certify that they are in rural, underserved locations. In addition, CMS proposed to change the payment methodology for the RHC and FQHC programs and implement new quality and safety standards. The NRHA shared serious concerns and reservations with CMS on the impact on the rural health safety net.
View our Comment Letter to CMS on the RHC and FQHC programs (August 26, 2008)
Hospital Inpatient PPS FY 2009 Proposed Rule
CMS annually releases a proposed and final year to detail the annual market basket update for hospital inpatient payments under the Prospective Payment System (PPS) and usually a variety of other proposals to the hospital system. This year, CMS proposed a variety of changes, including the final year of a three-year transition to MS-DRG payments, new quality measures, changes to the rural floor neutrality payments and a test of the Value Based Purchasing plan.
View our Comment Letter to CMS on the FY 2009 Hospital Inpatient PPS (June 13, 2008)
CAH TRICARE Reimbursement to be Cost Based
DoD released a rule proposing to change TRICARE's reimbursement of critical access hospitals (CAH). TRICARE's reimbursement will now mirror Medicare's, as required by law, and CAHs will receive payments of 101 percent of allowable and reasonable costs. While the NRHA endorses the DoD's proposal to pay CAHs nationwide cost-based reimbursement rates, we do have some concerns that there be full cost settlement to settle all costs.
View our Comment Letter to DoD on CAH Tricare Reimbursement (June 4, 2008)
Health Professional Shortage Area (HPSA)/Medically Underserved Population (MUP) Changes
On February 29, 2008, the HRSA published a proposed methodology for determining HPSAs and MUPs to combine the two shortage definitions under one formula. For providers relying on MUPs, this will for the first time require that the designation be updated periodically. The NRHA was concerned with a number of the details of the methodology, how it would be used by other programs and the anticipated implementation. Our biggest concern was that rural health clinics were not being treated fairly under the rule. For more information, see our Regulatory Guide.
View our Comment Letter to HRSA on the HPSA/MUP proposed changes (May 29, 2008)
Acronym key
CAH - Critical Access Hospital
CMS - Centers for Medicare and Medicaid Services
DoD - Department of Defense
FQHC - Federally Qualified Health Center
HRSA - Health Resources and Services Administration
PPS - Prospective Payment System
RHC - Rural Health Clinic
