NRHA CEO Alan Morgan Follows-Up with Dr. Berwick
[caption id="attachment_723" align="alignleft" width="150" caption="Dr. Berwick, 2011 NRHA President Kris Sparks, 2012 President Lance Kielers"][/caption] NRHA CEO Alan Morgan met today with CMS Administrator Berwick's staff as a follow-up to last week's Policy Institute conference in Washington, D.C. After a personal meeting at the conference with Dr. Berwick, NRHA President Kris Sparks, 2012 President Lance Kielers, and other NRHA staff, Dr. Berwick was very interested in further discussions about rural America's priorities and was quick to set up this opportunity for follow-up. Though there are many, many issues important issues important to rural America, Alan discussed the following list of issues currently relevant and important to NRHA membership: Physician Supervision (OPPS) The NRHA is pleased with CMS' decision to delay enforcement of its recent physician supervision requirements for CAHs and small PPS hospitals with less than 100 beds through 2011. We hope that any updated or final regulatory guidance on this issue takes safety and quality, as well as practicability of current practice, into account, and offer our assistance to CMS during any clinical review process that will lead to a long-term solution. Provider Tax (IPPS) Currently, hospitals can include certain taxes (provider taxes) paid to states relating to the "reasonable and necessary cost of providing patient care" and representing "costs actually incurred" when submitting Medicare cost reports to the Centers for Medicare and Medicaid Services (CMS). These taxes are levied upon hospitals in certain states to help fund Medicaid shares, and have long been considered a regular business operating cost for hospitals. In its recent federal regulations pertaining to the 2011 inpatient prospective payment system (IPPS) for acute and long-term care hospitals, CMS has proposed a "clarification" to pontetially disallow such provider taxes to qualify on hospital Medicare cost reports. This change would in fact have a significant impact on hospitals, specifically CAHs who are reimbursed based on their actual costs rather than fee-for-service. Provider taxes related to the costs of operating have long been considered regular business expenses for hospitals and therefore included as allowable costs on Medicare cost reports. Health IT/Meaningful Use (For more information, refer to NRHA health IT documentation) Rural providers face significant challenges and barriers in meeting meaningful use and other health IT benchmarks. While several ARRA HITECH provisions require that special attention be paid to the needs of rural healthcare, other ARRA legislative language inadvertently created vast inequities between CAHs and PPS hospitals. By any measure, rural healthcare organizations lag far behind their counterparts in terms of health information technology adoption. The NRHA urges CMS to recognize the unique challenges faced by rural providers and offer greater flexibility in meeting meaningful use guidelines. Additionally, we urge CMS and the Office of the National Health IT Coordinator to address any unfair treatment in the final ARRA language by granting rural providers access to any currently available grant funding. CAH "Direct Services" Guidance Medicare regulations [42CFR 485.635] stipulate that certain CAH services (ER, Radiology, Lab and General/Outpatient Services) must be provided by employed staff of the CAH, and not through an agency or contract. This provision has roots back to a CMS clarification of the Rural Primary Care Hospital (RPCH) program in 1994, the precursor to the CAH program. A State survey agency has cited a hospital for not being in compliance with this provision because it shared staff from a network hospital (the CAH didn't directly employ some of its employees).