August 21, 2013 - Volume 13, No. 4
OIG CALLS FOR CONGRESS TO ENFORCE CAH DISTANCE REQUIREMENTS
OIG CALLS FOR CONGRESS TO ENFORCE CAH DISTANCE REQUIREMENTS: PLACES MOST CAHS AT RISK IF CONGRESS ACTS
The U.S. Office of the Inspector General (OIG) recently released a report recommending that Critical Access Hospitals (CAHs) be stripped of their program status if they do not meet the distance standards established in the original federal CAH program. If this recommendation is adopted, almost all Washington State’s CAHs would lose their CAH designation and their cost-based reimbursement. Your Senators and Representative need to hear from you that this report is shortsighted, illustrates a lack of understanding of health care delivery in rural areas, and threatens health care services in your community.
The Centers for Medicare & Medicaid Services cannot implement this recommendation without Congressional action. Currently, there is no active legislation in Congress on this topic, but CAHs are at risk because of Congress's desire to cut spending. The OIG report increases this level of risk.
List of At-Risk Hospitals
Using Medicare rules, WSHA and the Department of Health have worked to determine the list of hospitals at risk of losing CAH status if Congress enacts the OIG’s recommendations. Click here to read the distance standards for Medicare.
Contact Your Congressional Members Today
Your Senators and Representative are home now. They need to hear from you before they return to D.C.! WSHA recommends sending your request to the Chief of Staff, Legislative Director, and Health Legislative Assistant. Please click here for a directory of Congressional Offices and staff. Please share the following message:
Message: “Recently, the U.S. Office of the Inspector General (OIG) released a report recommending that Critical Access Hospitals (CAHs) be stripped of their program status if they do not meet distance standards in the original federal CAH program. I am asking you to oppose this recommendation in Congress. As proposed by the OIG, because my hospital does not meet the original distance standards, we would lose cost-based reimbursement and face enormous budget cuts. If fully implemented, the report’s recommendations would cripple our ability to care for patients and devastate Washington State’s rural health care delivery system.
Cost-based reimbursement is the lifeline for my hospital and other important health care services in my community. Ninety percent of CAHs in Washington State operate primary care practices. Without cost-based reimbursement, my hospital would likely be forced to close or face a major loss of services, including primary care access. (Specify what you might close if you can.)
The OIG report fails to recognize the following key pieces about cost-based reimbursement and CAH status:
- Health care access is not just about funding, it is also about need. Many hospitals in our state qualify for CAH status under the “necessary provider exemption.” This exemption allowed states to take into account more than arbitrary geographic factors for CAHs—including, but not limited to, unemployment and poverty rates—when determining how to provide the best access to health care services for its residents.
- CAHs actually save Medicare money. CAHs provide cost-effective primary care. In fact, in comparing identical Medicare services in a rural setting to an urban setting, the cost of care in a rural setting is on average 3.7 percent less expensive. This focus on primary care, as opposed to specialty care, saves the Medicare program approximately $2.2 billion each year. This far exceeds the OIG's savings calculation.
- The closest hospital to many CAHs is another CAH. The report recommends eliminating CAH status for both hospitals – which could lead to broad geographic areas losing health care services.
- Some of the CAHs that do not meet the original distance standards are on the border of another state. State borders can present challenges to patients seeking services in other states. The OIG did not mention these challenges.”
WSHA will lobby against the OIG’s recommendation during our Rural Advocacy Days in Washington, D.C. on September 18 and 19. Hospital leaders and board members from around the state are coming to D.C. with WSHA. Please contact Wendy Ray at firstname.lastname@example.org or (206) 216-2516 if you would like to join us!
YOUR INPUT NEEDED: PHYSICIAN SUPERVISION THREATENS SERVICES
A move by the Centers for Medicare and Medicaid Services (CMS) could mean small hospitals would have to stop offering some services if they can’t provide direct physician supervision for outpatient therapeutic services. WSHA needs your help understanding the impact to care if this change went into place. CMS is proposing ending the moratorium for outpatient therapeutic services on January 1, 2014. The moratorium currently allows a general supervision standard for therapeutic services provided by Critical Access Hospitals and small rural hospitals with fewer than 100 beds. WSHA will submit a comment letter expressing disappointment in this decision. We need examples from hospitals about how the proposed rule would impact services. This information will be included in WSHA’s comment letter. Please submit this information to Chelene Whiteaker by Friday, August 23. More detailed information about this proposal is available in the most recent issue of Inside D.C. (Chelene Whiteaker, email@example.com)
For more information or questions, please contact Chelene Whiteaker at firstname.lastname@example.org or (206) 216-2545.