Good morning – CMS released the final CY25 regulation for the Physician Fee Schedule on Friday, and as expected, it included provisions related to RHC Operations, many of which were included in the "Rural Health Clinic Burden Reduction Act" (S.198| H.R.3730).
RHC Productivity Standards
RHCs are currently subject to productivity standards that can impact the AIR, if the productivity standards are not met. Productivity standards were first established in 1978 and updated in 1982 to help determine the average cost per patient for Medicare payment in RHCs as a cost control mechanism. Section 130 of the CAA, 2021, restructured the payment limits for RHCs beginning April 1, 2021. We believe that the productivity standards are outdated and redundant with the CAA, 2021 provisions; therefore, we are finalizing to remove these standards effective for cost reporting periods beginning on or after January 1, 2025.
RHC Conditions for Certification
CMS is finalizing changes to the RHC Conditions for Certification to increase flexibility and decrease provider burden, while also improving access to services for patients. Specifically, CMS is finalizing the proposal to explicitly require that RHCs must provide primary care services rather than being "primarily engaged" in furnishing these services, as indicated in the subregulatory guidance. The revised language more closely aligns with the intent of the statute while also preserving access to primary care services in communities served by RHCs.
Additionally, CMS is finalizing the removal of "hemoglobin and hematocrit (H&H)" and "examination of stool specimens for occult blood" from the list of laboratory services that RHCs must perform directly in the regulatory text. By finalizing the removal of these requirements, CMS anticipates facilities will see a decrease in the burden associated with purchasing and maintaining the laboratory equipment and having qualified staff needed to process these tests. Alleviating these burdens will allow RHCs to focus their resources on the other services they provide, thereby, improving overall efficiency and patient care. Lastly, CMS is also finalizing updates to the regulations text for laboratory tests in RHCs to reflect modern lab techniques.
Additional text is attached, but it looks like all good news.
Please feel free to reach out if you have any questions.
Kindest Regards,
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Chuck O'Neal
Director, Member Support
KPCA
Frankfort KY
(502) 545-9620
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