(Aug. 8, 2025) – Our partners with the Kansas Department of Health and Environment Facilities and Licensing Bureau report an increasing number of facilities have questions about the need to provide blood and blood products as a Critical Access Hospital.
In eCFR :: 42 CFR Part 485 Subpart F 618(c)(1)(2), the COPs for CAHs state that "The facility provides, either directly or under arrangements, the following: (1) Services for the procurement, safekeeping, and transfusion of blood, including the availability of blood products needed for emergencies on a 24-hours a day basis." The COPs for rural emergency hospitals refer to the same requirements and are found at eCFR :: 42 CFR Part 485 Subpart E 516(c)(3).
In the Interpretive Guidelines found at State Operations Manual - Appendix W, C-0890 found on page 70, the Centers for Medicare & Medicaid Services states that. "This requirement can be met at a CAH by providing blood or blood products on an emergency basis at the CAH, either directly or through arrangement, if that is what the patient's condition requires. There is no requirement in the regulation for a CAH to store blood on site, although it may choose to do so. In some cases, it may be more practical to transport a patient to the source of the blood supply than to bring blood to the patient at the CAH."
This may create confusion, as facilities may not believe they are required to provide it, since it technically doesn't have to be "on site." However, it has to be available 24/7, and they go on to say, "'Availability' in this context means that the blood and blood products must be accessible to CAH staff in time to effectively treat emergency patients at the CAH. In order to comply with this requirement, a CAH must demonstrate that it has the capability (i.e., an effective system is in place regardless of whether, in actual practice, it has been utilized) of making blood products available to its emergency patients 24 hours a day."
Please contact KHA if you have any questions or concerns at lvanderwege@kha-net.org.
--Larry Van Der Wege