CMS Rule Update Affecting Rural Health Clinics

Thoughtware Alert Feb 11, 2020
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Stethoscope and laptop

On September 26, 2019, CMS published the Omnibus Burden Reduction (Conditions of Participation) Final Rule CMS-3346-F, which impacts the policies and procedures for rural health clinics (RHC) and other entities. The new rules, effective November 30, 2019, affect RHC emergency preparedness exercises, training, communications, policy and procedure review and the Annual Program Evaluation.

According to CMS, the changes were made in an effort to reduce unnecessary burden for health care providers and remove or update “Medicare regulations identified as unnecessary, obsolete, or excessively burdensome on hospitals and other healthcare providers to reduce inefficiencies and moves the nation closer to a healthcare system that delivers value, high quality care and better outcomes for patients at the lowest possible cost.”

The following is a brief overview of the changes made through the final rule with links to the Federal Register:

  • The requirement to document efforts to contact local, tribal, regional, state and federal emergency preparedness officials in collaborative and cooperative planning efforts has been removed. However, RHCs will still be required to collaborate and cooperate and must have a related process included in the emergency preparedness policies. Read more.
  • The annual review of the emergency preparedness program policies has been changed to a biennial requirement. Read more.
  • The emergency preparedness program training requirement has been changed to a biennial requirement. However, RHCs will still be required to perform training when the emergency preparedness program is initially implemented as well as when significant updates are made to the program. Read more.
  • The requirement for emergency preparedness testing has been revised to require one community-based full-scale exercise, if available, or an individual facility-based functional exercise required biennially. In opposite years, an additional exercise is required and RHCs may choose the exercise method (full-scale community or facility-based or tabletop). Read more.
  • The RHC Annual Program Evaluation requirements and policy and procedure review have been changed to biennial requirements. Read more.

Note that while CMS has changed the frequency with which the functions listed above are performed, the importance of those functions has not decreased. CMS likely will expect the same or increased compliance with the requirements due to the reduced time burden RHCs face. Organizations that have not already complied with these requirements and documented their compliance should immediately update their policies and procedures and maintain documentation showing compliance with the requirements in case it is requested by CMS, particularly during recertification surveys.

BKD can provide organizations with numerous RHC services, including assistance with policy and procedure reviews, participation in program evaluations and mock surveys, to help comply with RHC program requirements. If you have questions or need assistance, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.

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