2019 RHC UPDATES ROBIN VELTKAMP/TRESSA SACREY HEALTH SERVICES ASSOCIATES
CMS UPDATES on Appendix G
CMS UPDATES • DATE: September 3, 2019 • TO: State Survey Agency Directors • FROM: Director Survey and Certification Group • SUBJECT: Revised Rural Health Clinic (RHC) Guidance Updating Emergency Medicine Availability—State Operations Manual (SOM) Appendix G- Advanced Copy
CMS UPDATES • Memorandum Summary • • RHC Appendix G Revision: The Centers for Medicare & Medicaid Services (CMS) is updating the medical emergency guidance as it pertains to the availability of drugs and biologicals commonly used in life saving procedures.
CMS UPDATES • The current guidance clarifies that an RHC must maintain a supply of drugs and biologicals adequate to handle the volume and type of emergencies it typically encounters for each of the listed categories. It further states, if an RHC generally handles only a small volume/type of a specific emergency, it is appropriate for the RHC to store a small volume of a particular drug/biological. As an example, we used snake bites as a medical emergency to which storing a small volume of an antidote would be acceptable.
CMS UPDATES • CMS understands the potential financial burden to which RHCs may face as a result of the current guidance. After further view of the regulatory language, we believe the use of “such as” in relation to the drug/biological types described at 42 CFR 491.9(c)(3), does provide some flexibility to RHCs. Therefore, we are revising Appendix G
CMS UPDATES • 1.9(c)(3), does provide some flexibility to RHCs. Therefore, we are revising Appendix G. Specifically, when determining which drugs and biologicals to have available in order to provide medical emergency procedures as a first response to common life-threatening injuries and acute illnesses, an RHC must consider each of the categories listed in regulation. While each category of drugs and biologicals must be considered, all are not required to be stored.
CMS UPDATES • An RHC must have those drugs and biologicals that are necessary to provide its medical emergency procedures to common life-threatening injuries and acute illnesses. In making this determination, the RHC should consider, among other things, accepted medical standards of practice, community history and the medical history of its patients. The RHC should have written policies and procedures for determining what drug/biologicals are stored to provide such emergency services.
CMS UPDATES • The policy and procedures should also reflect the process for determining which drugs/biologicals to store, including who is responsible for making this determination. They should be able to provide a complete list of which drugs/biologicals are stored and in what quantities
CMS UPDATES • Survey Procedures § 491.9(c)(3) • Review the RHC’s written policies and procedures to determine the types and quantities of drugs/biologicals it stores for medical emergency purposes, • Review all of the drugs/biologicals that are stored and available in the RHC, including in what quantities, to verify the RHC maintains a supply of commonly used drugs and biologicals adequate to handle the volume and type of medical emergencies it typically encounters.
CMS UPDATES • Ask RHC staff how they determine the quantity and specific types of drugs and biologicals to have on hand. How do they ensure that the specified drugs and biologicals are on hand in the quantities specified per RHC policy and have not expired?
CMS UPDATES on Burden Relief
BURDEN RELIEF NOVEMBER 2019 • AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS. ACTION: • Final rule.
BURDEN RELIEF NOVEMBER 2019 • Over the past several years, we have revised our requirements, Conditions of Participation (CoPs) and Conditions for Coverage/Conditions for Certification (CfCs) to reduce the regulatory burden on providers and suppliers while emphasizing health and safety. We identified obsolete and burdensome regulations that could be eliminated or reformed to improve effectiveness or reduce unnecessary reporting requirements and other costs, with a particular focus on freeing up resources that health care providers, health plans, and States could use to improve or enhance patient health and safety.
BURDEN RELIEF NOVEMBER 2019 • Emergency Preparedness Requirements: Requirements for Emergency Plans • We are removing the requirements from our emergency preparedness rules for Medicare and Medicaid providers and suppliers that facilities document efforts to contact local, tribal, regional, State, and Federal emergency preparedness officials, and that facilities document their participation in collaborative and cooperative planning efforts.
BURDEN RELIEF NOVEMBER 2019 • Emergency Preparedness Requirements: Requirements for Annual Review of Emergency Program We are revising this requirement so that applicable providers and suppliers review their Emergency program biennially, except for Long Term Care facilities, which will still be required to review their emergency program annually
BURDEN RELIEF NOVEMBER 2019 • Emergency Preparedness Requirements: Requirements for Training • We are revising the requirement that facilities develop and maintain a training program based on the facility’s emergency plan annually by requiring facilities to provide training biennially (every 2 years) after facilities conduct initial training for their emergency program, except for long term care facilities which will still be required to provide training annually. In addition, we are requiring additional training when the emergency plan is significantly updated.
BURDEN RELIEF NOVEMBER 2019 • Emergency Preparedness Requirements: Requirements for T esting • For inpatient providers, we are expanding the types of acceptable testing exercises that may be conducted. For outpatient providers, we are revising the requirement such that only one testing exercise is required annually, which may be either one community-based full- scale exercise, if available, or an individual facility-based functional exercise, every other year and in the opposite years, these providers may choose the testing exercise of their choice.
BURDEN RELIEF NOVEMBER 2019 • CAH Annual Review of Policies and Procedures We are changing the requirement at § 485.635(a)(4) to require a CAH’s professional personnel to, at a minimum, conduct a biennial review of its policies and procedures instead of an annual review.
BURDEN RELIEF NOVEMBER 2019 • Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Review of Patient Care Policies We are revising the requirement at § 491.9(b)(4) that RHC and FQHC patient care policies be reviewed at least annually by a group of professional personnel, to review every other year in order to reduce the frequency of policy reviews
BURDEN RELIEF NOVEMBER 2019 • RHC and FQHC Program Evaluation We are revising the requirement at § 491.11(a) by changing the frequency of the required RHC or FQHC evaluation from annually to every other year.
BURDEN RELIEF NOVEMBER 2019 • Additional information 393 pages that impact various types of entities • https://www.federalregister.gov/documents/201 9/09/30/2019-20736/medicare-and-medicaid- programs-regulatory-provisions-to-promote- program-efficiency-transparency-and
CMS UPDATES on Modernization Act
RHC MODERNIZATION ACT • On April 4, 2019, S. 1037 was introduced to the 116 th Congress. • Section 1: • Short Title: Rural Health Clinic Modernization Act of 2019
RHC MODERNIZATION ACT • Section 2: • Update Physicians, Physician Assistants and Nurse Practitioner utilization requirements • Old Language – “Has an agreement” • New Language – “Meets the requirements” • Allows for mid-level providers to work at the top of their State Licensure requirements
RHC MODERNIZATION ACT • Section 3: • Remove outdated laboratory requirements • Old Language – “ including clinical laboratory services …and additional diagnostic services” • New Language – “has prompt access to clinical laboratory services and additional diagnostic services
RHC MODERNIZATION ACT • Section 4: • Allow RHC clinics the flexibility to contract with Physician Assistants and Nurse Practitioners • Old Language – “Employs” a PA or NP • New Language – “AND”
RHC MODERNIZATION ACT • Section 5: • Allow Rural Health Clinics to be the distant site for telehealth visits • Old Language – “A practitioner” • New Language – “practitioner OR rural health clinic
RHC MODERNIZATION ACT • Section 6: • Include facilities located in certain areas • Old Language – “located in a rural area that is designated as a shortage area” • New Language – “…shortage area OR in an area that has been designated by the chief executive office of the State and certified by the Secretary as rural
RHC MODERNIZATION ACT • Section 7: • Increase reimbursement for Rural Health Clinics • In 2020, at $105 per visit • In 2021, at $110 per visit • In 2022, at $115 per visit
RHC MODERNIZATION ACT • The bill was read twice and forwarded to the Committee on Finance.
Recommend
More recommend
