CMS Update Critical Access Hospitals: Compliance with Location and Distance Requirements

From HFAP (hat tip: Dr. Sue Nedza):

Key Points:

  1. The S&C letter defines the responsibilities for Regional Offices (RO) to determine which CAHs meet the status and location requirements. The RO must complete a “CAH Recertification Checklist: Rural and Distance or Necessary Provider Verification” form and save in the respective CAH’s file.
  2. Once the RO determines a particular CAH is currently in compliance with the rural status and distance requirements, it will contact the State Agency and Accreditation Organization to advise them that a recertification or reaccreditation survey may be conducted.
  3. State Agencies (SA) and Accreditation Organizations (AO) may NOT conduct a recertification / reaccreditation survey of a CAH that does NOT meet the rural status and location requirements.
  4. A CAH may request review of its CMS’ determination that a CAH is not a necessary provider if, within 60 days of the date of a CMS letter that communicates the agency’s determination that the CAH distance requirements have not been met, it submits supplementary evidence to the CMS RO for CMS’ consideration. The burden is on the CAH to provide qualifying evidence demonstrating that necessary provider designation was made by the state prior to January 1, 2006, and that the designation was applicable to the specific facility in question.
  5. If it is determined that a CAH does not meet the rural status and distance requirements, the RO will send a letter notifying the CAH that its CAH status will be terminated. The letter instructs the CAH of its options which may include:
    1. Attempt to reclassify as rural,
    2. Convert to hospital status, or
    3. Have its Medicare participation terminated.

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