The NRHA submitted the following comments to CMS regarding its proposed guidelines for the first stage of the American Recovery and Reinvestment Act (ARRA) electronic health record (EHR) incentive payment program.  The proposed rule is the first in a series of CMS guidelines relating to ARRA's Meaningful Use standards.  While the NRHA believes widespread adoption of EHR is a key component to fixing many of rural America's current health barriers, we also have significant concerns with a number of the proposed rule's provisions. 

The NRHA has commented on two net neutrality rules proposed by the Federal Communications Commission. "A National Broadband Policy is of particular interest to the NRHA, especially as it pertains to the intersection of rural healthcare and broadband Internet access," said Alan Morgan, CEO. "I am hopeful that the proposed additional net neutrality principles will receive the scrutiny from the FCC that they deserve as we look forward to increasing rural broadband Internet deployment and access, supporting the use of telemedicine, and promoting reasonable network management as it relates to lifesaving applications."

To read the full comments, click here.

NRHA recently submitted comments to the CMS proposed rule for changes to the 2010 Outpatient Prospective Payment System (OPPS), which were due on August 31. NRHA commented on sections related to physician supervision provisions important to maintaining patient access to rural hospitals, as well as proposals on outpatient quality and data requirements, specified covered outpatient drug payments, and the continuation of the 7.1 percent add-on “hold harmless” payment to rural hospitals.

For the entire document, please click here. 

Each year the NRHA membership produces a Legislative and Regulatory Agenda that details the policy agenda of the association. As we prepare for 2010, we ask all members to take some time to read the 2009 Agenda and suggest any needed additions, changes or amendments. You can submit these changes via an online form.  Submissions are due September 3.

On June 29, the Health and Human Services Department rescinded three controversial Bush Administration regulations governing Medicaid and said it would postpone and possibly change or rescind a fourth. These regulations are among seven that were proposed by the Bush Administration and rigorously opposed by NRHA. Congress placed a moratorium on the regulations last summer in the War Supplemental Bill, but it was set to expire on June 30, allowing the regulations to go into effect.

On May 1, the Centers for Medicare and Medicaid Services released the FY2010 inpatient prospective payment system (IPPS) proposed rule. This rule completes the agency's fiscal year proposal.

NHRA recently submitted comments to the CMS on the rule. The proposed changes, which are released every year for public comment, included strong fixes for rural Medicare disparities but also many changes that would directly impact many rural beneficiaries in a negative way. NRHA strongly urged CMS to ensure any changes to the way providers were reimbursed would not result in more limited access than the rural American health care infrastructure already faces. The proposed changes include: 

• Reconfiguring statistical geographic areas for wage index classification
• Changes requiring sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs) to be subject to document and coding adjustments (DCA)
• Electronic health record (EHR) and health information technology (HIT) reimbursement compliance standards
• Changes affecting critical access hospitals

To view the letter to CMS with a complete list of NRHA's comments, please click here.

To read the proposed rule, click here.