Premier submitted comments on the Conditions of Participation (CoPs) for Rural Emergency Hospitals (REH) and Critical Access Hospital (CAH) CoP Updates proposed rule. In its comments, Premier urges CMS to:
- Work with Congress to modify relevant statute to address statutory restrictions that could make this new provider type financially untenable for many hospitals or may result in the loss of other services to rural communities;
- Adopt permanent staffing and workforce flexibilities to enable REHs to align their workforce with the needs of their communities;
- Finalize its decision to not limit the types of outpatient services that REHs can choose to furnish;
- Clarify the requirements for REHs operating provider-based rural health clinics and establish clear guidance that would allow REHs to share space with other types of providers;
- Explore ways to support REHs and other rural providers in implementing electronic health records and electronic clinical surveillance technology to provide meaningful assistance with infection control;
- Consider excluding federal numbered highways with one lane in each direction from the definition of “primary roads” that is used to satisfy the CAH distance requirement;
- Continue to practice enforcement discretion of the 96-hour certification requirement after the conclusion of the PHE and classify it as a low-priority item for auditors; and
- Continue to work with stakeholders to adapt existing alternative payment models to be more inclusive of rural providers, including REHs, and to ensure rural providers have the necessary flexibilities and tools to succeed in value-based care.