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President Trump Signs Legislation to Combat Opioid Crisis

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

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 Regulator Burden

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

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

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

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

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 Claims

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

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

Bill Finerfrock, Executive Director

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Palmetto "Outpatient Services Incorrectly Paid"

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

Nathan Baugh, Director of Government Affairs

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Updates From Palmetto

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

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

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)

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)

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

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

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

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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