(Aug. 26, 2022) – The Kansas Hospital Association and our members have been working hard to learn as much as possible about the new Rural Emergency Hospital model since the Consolidated Appropriations Act passed in December 2020, especially with the recent release of the Medicare Conditions of Participation and Outpatient Prospective Payment proposed rule.
Since 2012, KHA has been partnering with member hospitals to explore alternative rural health models for Kansas communities. After thoughtful consideration, the concept developed by the membership was referred to as the Primary Health Center model. The PHC model offered a sustainable option for rural areas to provide preventive and primary care, chronic disease management and emergency services; serve as an access point, and coordinate care for the individual when higher levels of service are required.
After many years of working with the Kansas congressional delegation and advocating for the opportunity to test this concept, we were pleased about the passage of Rural Emergency Hospital. The REH is a new payment and delivery model that is very similar to the Primary Health Center model and is a permanent solution for rural communities to consider. REHs can start operating in January 2023.
Similar to the Primary Health Center model, the Rural Emergency Hospital provides ambulatory, initial assessment and interventional services. The REH is open to the community every day of the year to provide the consistent service array most needed by the community. It will focus on the primary care needs of the community and be supported by a robust EMS plan and a wide array of telemedicine services. The Medicare payment methodology for Rural Emergency Hospitals includes an annual facility payment, which is a good first step. We also will continue to evaluate how Medicaid and private payers will reimburse under this model.
Since the release of the Medicare Conditions of Participation and Outpatient Prospective Payment proposed rule this summer, KHA has established a membership committee to delve deeper into the REH model and better understand its difference from the PHC model. Our membership committee recently met to begin developing a list of questions and issues that we plan to raise in the comment letter to the Centers for Medicare & Medicaid Services. The COP comments are due at the end of August.
While not a comprehensive list, some of the items raised during our committee meeting seek clarification on the impact of the REH program on provider-based RHCs, flexibility for REHs to operate swing-beds, ability to participate in the 340B program, and eligibility for hospitals that have closed over the past several years. In addition, we are asking for as much consistency as possible between the CAH COPs and the REH COPs. Some of these changes may be clarified when the rules are finalized while others may necessitate congressional approval.
To assist interested hospitals and communities in moving forward, we have already started to pave the way for this opportunity. The federal requirements state that in order for a facility to convert to an REH, the hospital must be in a state that provides for licensing of an REH. Anticipating this requirement, Kansas was one of the first states to create this new licensure category for REHs.
It continues to be important that we engage communities in conversations about the future of health care in our state. KHA continues to work in partnership with the United Methodist Health Ministry Fund and the KU Public Management Center to provide opportunities to host Community Conversations on rural health care in Kansas. If you are interested in REH or conducting a community conversation in your area, please let me know or reach out to Jennifer Findley at (785) 233-7436.