The National Rural Health Association submitted its comment letter this week in response to CMS' proposed changes affecting Hospital and Critical Access Hospital (CAH) Conditions of Participation (CoPs) Credentialing and Privileging of Telemedicine Physicians and Practitioners.  The letter voices the NRHA's gratitude that CMS is seeking to lessen the duplicative burdens associated with credentialing and privileging professionals performing telemedicine services via larger distant "hub" hospitals, but also our concern that its limited scope does not reach far enough to include accredited non-hospital telemedicine services.  Under the proposed guidance, hospitals utilizing accredited non-hospital telemedicine services, for instance smaller ambulatory care or tele-radiology centers, will still be required to perform credentialing and privileging services even if those distant-site professionals are accredited through the service from which they operate. 

HHS Secretary Kathleen Sebelius announced today a revised membership list for the Health Resources and Services Administration's (HRSA) Health Professional Shortage Area (HPSA) and Medically Underserved Areas/Populations (MUA/P) negotiated rulemaking committee. 

The new list, which has increased from 24 to 28 members, includes National Rural Health Association CEO Alan Morgan as a participant.  Previously excluded from the committee, the NRHA fought to fix this obvious oversight by HRSA.  This effort's success was due in large part to the help of the numerous NRHA members and friends who offered to call and write Dr. Wakefield and their Congressional representatives to ensure broad rural representation on the committee.  For this, we are extremely grateful.  Additionally, the NRHA greatly appreciates Dr. Wakefield and HRSA for their willingness to reassess the committee makeup and their continued commitment to improving health care in rural America.   

The National Rural Health Association (NRHA) congratulates HHS on today's release of final rules regulating criteria for the electronic health record incentive program or 'meaningful use,' and the release of final criteria for EHR standards necessary for vendor products to meet meaningful use certification.  The final rule adopts significant changes and reflects many of the concerns raised by the NRHA during the comment period.

On Wednesday, the White House appointed Donald M. Berwick to the position of Administrator of the Center of Medicare and Medicaid Services.  The Obama administration is using this week's congressional recess to bypass a Senate confirmation hearing in a move known as a "recess appointment."  However, since Mr. Berwick's appointment comes without congressional confirmation, the appointment only lasts one calendar year. 

The NRHA submitted the following comments to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed changes to the 2011 Inpatient Prospective Payment System for acute and long-term care hospitals, and its supplemental proposed rule based on the recent health reform bill's requirements. 

On June 18, 2010, the Office of the National Coordinator for Health Information Technology issued a final rule that establishes a temporary program for certification of electronic health record technology.  This program sets the guidelines that organizations need to follow in order to be authorized by the National Coordinator to test and certify their EHR Technology.

Using "Certified EHR technology" is a requirement for providers seeking to qualify for incentive payments under provisions authorized in the Health Information Technology for Economic and Clinical Health Act that was enacted as part of the American Recovery and Reinvestment Act of 2009.

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.