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December 18, 2008
The next RHC TA call has been scheduled for January 13, 2009 at 2:00 pm EASTERN. The topic will be RHC Billing and our speaker will be Charles James, President of North American Healthcare Management Services. Slides and call-in information will be distributed approximately one week before the call.
Also, CMS has announced the RHC cap for 2009. Effective for services provided on or after 1/1/2009, the cap will be $76.84. The cap in 2008 has been $75.63. The 2009 rate reflects a 1.6 percent increase over the 2008 payment limit.
If you would like to view a copy of the transmittal sen to the RHC fiscal intermediaries or MAC's, go to: http://www.cms.hhs.gov/transmittals/downloads/R1626CP.pdf
Finally, I've received several inquiries about the status of the proposed changes in the RHC rules.
Although the Bush Administration will be in office until January 20, 2009, it is unlikely that CMS will seek to publish any changes in the RHC rules and regulations prior to leaving office. Consequently any decision on what - if anything - to do with the RHC proposed rule will have to be made by the Obama Administration.
We anticipate it will take several months for the new Administration to make any decisions on rules and regulations left over from the Bush Administration. NARHC will seek to meet with the new leadership at both the Department of Health and Human Services and the Center for Medicare and Medicaid Services as soon as possible. A new CMS Administrator may not be in place until February or March.
RHC Proposed Rule Comment Period - August 25, 2008
Earlier today, CMS responded to the Congressional and organizational requests for a 60 day extension of the proposed rule comment period by saying NO. Consequently ALL comments in response to the RHC proposed rule must be submitted by 5:00 pm (EASTERN) tomorrow, August 26th.
If there is any good news in all of this, it is that several of the Senators who requested the extension are extremely upset with CMS's refusal to grant this reasonable request. We are in the process of working with these offices to develop a strategy to prevent the unnecessary and inappropriate closure of Rural Health Clinics.
In the meantime, I want to urge everyone to submit comments on the proposed changes. If we have any hope of getting CMS to make the changes necessary to prevent the inappropriate closure of RHCs, then it is imperative that you write.
NARHC Draft Comments
Attached is a copy of the draft comments NARHC intends to submit prior to the August 26th deadline. It is possible that some changes will be made. It is being reviewed for content and it is also being reviewed for typographical and grammatical errors. (Click here for draft comments)
You are encouraged to review these comments and where you think appropriate, submit comments similar to those incorporated in the NARHC document. I would ask that when submitting comments, be as specific and heartfelt as possible. Explain the situation in your community and most importantly, what these proposed changes may mean for access to health care in your community.
Realistically we don't expect CMS to accept everything we've recommended but if we don't ask, it can't happen. Some of these proposals go a bit farther than some might like but again, if you don't push the extremes, you can't change the middle ground either.
Your feedback (with what little time we have) would be appreciated.