Archived News


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What's New for RHCs in 2019?
1/10/2019

Nathan Baugh, Director of Government Affairs

Calendar year 2019 is here, and with it comes a flurry of new benefits and policies for Rural Health Clinics to keep track of. The following is a quick summary and update of what has changed and what is new for RHCs in 2019:

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President Trump Signs Legislation to Combat Opioid Crisis
10/29/2018

Nathan Baugh, Director of Government Affairs

On October 24th, President Trump signed into law the "SUPPORT for Patients and Communities Act." This legislation represents the culmination of bipartisan efforts to combat the opioid crisis gripping our country. In an otherwise partisan environment, the SUPPORT for Patients and Communities Act passed the Senate (98 to 1) and the House (396 to 14) with overwhelming bipartisan majorities.

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NARHC Pitches Modernization Legislation On Capitol Hill
10/1/2018

Nathan Baugh, Director of Government Affairs

On September 20th, a small contingent of individuals from across the Rural Health Clinic (RHC) community and country came to Washington D.C. for a series of meetings with Congress on modernizing the RHC statute. This "fly-in" was organized and coordinated by NARHC as part of an effort to build support for legislation that we hope will pass this year or early next year.

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CMS Seeking to Reduce RHC Regulatory Burden
9/21/2018

Nathan Baugh, Director of Government Affairs

CMS released a proposed rule on September 20th seeking to reduce unnecessary regulatory burdens within the Medicare program. The goal of the proposal is to allow health care professionals to focus more resources and time on providing care by reducing regulatory requirements that might impede that.

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CMS Proposed E&M Coding Changes Medicare RHC
8/23/2018

Bill Finerfrock, Executive Director

Q: The new Medicare payment proposals includes an option to pay a flat rate ($93 fee) sounds like what we already have as an RHC with our AIR. That proposed rate is higher than the current cap for the AIR for Ind. RHC's. If this goes through, what would be the point of continuing as an RHC for Medicare? A: It is an interesting question and one that we (NARHC) leadership and staff have discussed... ...What is NARHC doing with respect to the RHC Cap?

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CMS Requests Palmetto GBA Indefinitely Delay Its' Plans to Auto-Cancel Claims
8/4/2018

Bill Finerfrock, Executive Director

Palmetto GBA and CMS have received a number of inquiries from providers and their representatives concerning provider appeal rights as well as information on how impacted providers may re-bill responsible MA plans. CMS is working to address these concerns and provide information to MA plans that will help them be better able to identify any rebilled claims from providers. So as to afford the agency with the time needed to develop complete guidance on these topics, CMS has requested...

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CMS Proposes New "Virtual Check-In" and "Remote Evaluation" Benefit for RHCs
7/13/2018

Nathan Baugh, Director of Government Affairs

Despite the fact that Rural Health Clinics are not paid under the physician fee schedule, significant updates and changes for the RHC program are often included in the Physician Fee Schedule rulemaking process. Yesterday, CMS released their thousand-plus page 2019 Physician Fee Schedule proposed rule. One major takeaway for RHCs is the proposal of a new "virtual check-in" service...

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Palmetto Recoupment One-Month Filing Extension of "Improperly" Paid Claims
7/11/2018

Bill Finerfrock, Executive Director

Yesterday I expressed my disappointment that the most recent posting by Palmetto regarding challenges to the recoupment notices did not reflect an understanding we had reached with CMS last week. Specifically, that RHCs would have until mid-August to file reconsideration notices for recoupments they felt were in error. I communicated to CMS officials our disappointment with the posting and that it did not reflect what CMS said they would do. Yesterday afternoon, I received an update...

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Update on Palmetto Recoupment of "Improperly" Paid Cliams
7/10/2018

Bill Finerfrock, Executive Director

Last week I had a meeting with senior leaders at CMS to discuss the efforts by Palmetto to recoup monies they believe were improperly paid by Cahaba for Medicare beneficiaries enrolled in MA plans at the time the services were rendered. When that call ended, I believed we had an agreement... ... Late yesterday I was given an update - put out by Palmetto - that does NOT reflect the agreement I felt had been reached...

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Palmetto Recoupment Update
7/3/2018

Bill Finerfrock, Executive Director

As you know from my previous posts, NARHC continues to work on the Palmetto recoupment problem. To say that this is a mess would be an insult to anything I've previously described as "a mess." While I appreciate efforts by Palmetto to be responsive, the options they seem to have available for a fair resolution of this problem seem limited. For this reason, we are taking this issue to the highest levels at CMS...

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Palmetto Recoupment Educational Letter
7/2/2018

Bill Finerfrock, Executive Director

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Palmetto "Outpatient Services Incorrectly Paid"
6/22/2018

Nathan Baugh, Director of Government Affairs

NARHC has been in contact with Palmetto regarding the letters sent to RHCs this month Re: "Outpatient Services Incorrectly Paid by Medicare for Beneficiaries under a Medicare Advantage Plan." Palmetto has informed us that additional communications are forthcoming on Monday, June 25th, which should address some of the concerns we have heard from the RHC community including:

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Palmetto Audio Notification
6/21/2018

Nathan Baugh, Director of Government Affairs

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Updates From Palmetto
6/19/2018

We have been asked by Palmetto to share the following with the RHC Community. If you are not in the Palmetto service area, you can disregard this posting...

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2018 MIPS Eligibility Tool
4/19/2018

The CMS has released it's 2018 MIPS Participation Lookup Tool. You may use the updated Lookup Tool to check your eligibility in 2018 for the Merit-based Incentive Payment System (MIPS). Rural Health Clinic providers can enter their National Provider Identifier (NPI) to find out if they're required to participate during the 2018 performance year.

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New Medicare Card
3/29/2018

Beginning in April 2018, the Centers for Medicare & Medicaid Services (CMS) will start mailing new Medicare cards to all people with Medicare. The roll-out will occur over a several month period based upon the geographic location of the Medicare beneficiary. You are encouraged to talk with your Medicare patients about this so they are aware of the transition and do not think that this is a "scam".

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CMS Publishes AAPM Table (Advanced Alternative Payment Models)
2/5/2018

Today, the Centers for Medicare and Medicaid Services (CMS) published a table displaying the Alternative Payment Models (APMs) that CMS operates. In the table CMS identifies which of those APMs CMS has determined to be MIPS APMs or Advanced APMs. We will modify this list based on changes in the designs of APMs or the announcement of new APMs. See the table here...

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State Operations Manual (SOM) Appendix G - (Guidance for Surveyors: Rural Health Clinics)
2/2/2018

CMS recently released a new version of the State Operations Manual (SOM) Appendix G. This document contains significantly more detailed interpretive guidelines for RHC survey and certification than the previous version. If you have questions on how to meet the RHC rules and regulations, this document will likely have the answers you seek.

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National Advisory Committee on Rural Health and Human Services Recommendations
1/24/2018

The National Advisory Committee on Rural Health and Human Services (NACRHHS), recently released their policy brief and recommendations on how to "Modernize Rural Health Clinic Provisions." The NACRHHS picks one or two issues a year and produces a policy brief(s) for the Secretary of HHS...

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Laboratory Billing
1/10/2018

A Program Memo issued by CMS (at the time known as HCFA) which addresses laboratory billing by both independent and provider-based RHCs, states: Laboratory In light of recent inquiries regarding laboratory services, we are clarifying whether diagnostic laboratory tests furnished in the RHC/FQHC by their personnel are covered RHC/FQHC services paid under the all-inclusive rate, or whether such services are beyond the scope of RHC/FQHC services. While the law requires...

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Essential Community Provider Designation
12/15/2017

Are you an Essential Community Provider (ECP)? Most Rural Health Clinics will answer that question with a resounding YES! But for many Health Plans sold on the Affordable Care Act (ACA) Exchanges, the answer is often a resounding "maybe." Why, because many RHCs have failed to petition for ECP designation...

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RHCs Serviced by Cahaba
11/20/2017

As you should have heard, Cahaba has lost their contract as a Medicare Administrative Contractor (MAC) for Jurisdiction J (JJ) (Alabama, Georgia, Tennessee). The new contractor for MAC Region J (JJ) will be Palmetto GBA. Jurisdiction J (JJ), in addition to handling Medicare Part A and B claims for the three states mentioned above, was also the "legacy" MAC for hundreds of RHCs located outside of Jurisdiction J (JJ). This is a link...

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Emergency Preparedness
11/2/2017

November 15th is fast approaching and all RHCs must have taken steps to be in compliance with the new Emergency Preparedness requirements CMS will begin enforcing on that date.

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MACRA Proposed Rule for 2018
6/27/2017

Nathan Baugh, Director of Government Affairs

Last week, CMS released their 1,050 page MACRA proposed rule for calendar year 2018. The big proposed change is an increase in the low-volume threshold for participation in MIPS to $90,000 (up from $30,000) of Medicare allowable revenue or 200 (up from 100) Medicare part B patients. This proposed change should exempt most RHC clinicians from the MIPS program. As a refresher...

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NARHC Website has New Look + Increased SSL Security
6/14/2017

The NARHC Website has a new look & feel plus additional SSL security! We hope you like it!

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RHC Guidelines & Emergency Preparedness
6/13/2017

Please note that the RHC Guidelines & The Emergency Preparedness have undergone some recent changes. Check them out on our website.

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NARHC Addresses Senate Press Conference
5/23/2017

The National Association of Rural Health Clinics (NARHC) was invited to speak at a Senate press conference on rural health hosted by Senator Martin Heinrich (D-NM). NARHC President John Gill stressed the important role Medicaid plays in allowing RHCs to provide care in rural communities...

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Raising the RHC Cap?
4/26/2017

Bill Finerfrock, Executive Director

A question was posed about the prospects for raising the RHC cap and when this might occur. Raising the RHC cap requires an Act of Congress as the cap is set by law. The current cap is an extension of the RHC cap established in 1988 ($46.00 per visit) adjusted for medical inflation over the intervening 29 years. Obviously it is very out-of-date...

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Policy & Procedure Manual Template
4/18/2017

Bill Finerfrock, Executive Director

Below are some options. I would strongly recommend that you use these as templates. Also, please note that the P/P manual in the "How To" publication is getting old and likely needs to be updated but it will still give you a sense of how you may want to proceed. It is extremely important that the P/P manual be a reflection of how YOUR RHC intends to practice and see/treat patients.

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Are Visits to an SNF by an RHC Provider an RHC Visit?
3/27/2017

Bill Finerfrock, Executive Director

Recently, an NARHC News listserve participant posted a question/concern regarding a comment she heard during a webinar conducted by the Medicare MAC - Noridian. The commenter stated that the representative from Noridian stated that visits to a SNF by an RHC provider were not RHC visits and should be billed on the 1500 claim form and not billed on the UB-04. If correct, this would constitute a significant change in CMS policy (as well as the Medicare statute). NARHC contacted...

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Updates from Cahaba on RHC Claims
11/29/2016

Bill Finerfrock, Executive Director

ALL RHC Medicare claims - whether "single line" or "multi-line' MUST have the CG modifier on the "pay" line. If a single line, the CG modifier goes on the single line with the HCPCS code for that RHC visit. If multi-line, then the CG modifier goes...

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CG Modifier & Cahaba
11/23/2016

Nathan Baugh, Director of Government Affairs

As many of us know, beginning October 1, most RHC Medicare claims (with a few exceptions) were required to have modifier CG on the claim. While we (NARHC) communicate billing updates through this listserv as soon as we learn about them, this is ultimately a responsibility of each MAC to communicate these updates to their jurisdiction. NARHC staff has discovered...

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Election First Take Analysis
11/10/2016

Bill Finerfrock, Executive Director

The following is our quick analysis of the election for your reading pleasure. NARHC will also be creating a more RHC-centric analysis and sending that out sometime next week via List Serve...

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2017 Physician Fee Schedule Final Rule – RHC Provisions
11/4/2016

Nathan Baugh, Director of Government Affairs

While many of you were probably watching the Chicago Cubs win their first world series since 1908, we at the NARHC, were diligently reviewing the 2017 Physician Fee Schedule Final Rule for RHC related provisions. These provisions are effective as of January 1, 2017. You can find the final rule here...

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RHC Guide to the MACRA Final Rule
10/28/2016

We understand that there are a lot of questions and interest around MACRA (Medicare Access and CHIP Reauthorization Act) especially around the specifics of how it does and does not affect RHCs. We have put together the following Q&A to address many of the relevant aspects of the final rule for RHCs.

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CG Modifier
10/26/2016

Bill Finerfrock, Executive Director

CMS has produced an FAQ document that addresses many of the questions/scenarios relative to the use of the CG modifier that have been raised on this listserve. I strongly encourage you to review this document.

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HCPCS Reporting
10/1/2016

Nathan Baugh

Hopefully everyone is aware of the HCPCS reporting changes set to kick in next week. The best place to review those changes is HERE. We also wanted to clarify a few things regarding these changes...

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HCPCS Reporting Requirements Starting Oct. 1st
10/1/2016

Nathan Baugh, Director of Government Affairs

CMS recently released a new MLN Matters article detailing the new HCPCS reporting requirements starting on October 1, 2016. The article can be accessed HERE. As expected, we will no longer have to deal with a qualifying visit list. Instead...

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2018 Essential Community Provider List & Petition
9/1/2016

Under the Affordable Care Act (ACA), Qualified Health Plans (QHPs), are required to include essential community providers (ECPs) that serve predominantly low-income, medically-underserved individuals in their networks Rural Health Clinics are eligible for designation as ECPs. As part of the Plan Approval process, the Secretary Health and Human Services (HHS) has established...

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2017 Physician Fee Schedule Updates
7/13/2016

Nathan Baugh, Director of Government Affairs

On July 6th, the Centers for Medicare and Medicaid Services (CMS) released the 2017 Physician Fee Schedule (PFS) proposed rule. This is one of the major annual rules CMS uses to announce proposed changes to the Medicare program. Most notably for RHCs, this year’s PFS makes numerous changes to the RHC Chronic Care Management (CCM) requirements, including changing the supervision requirement that we believe are welcome and should make it easier to implement CCM services.

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