Home Health Shortage Area Declaration

May 12, 2020

To:                      Chief Executive Officers of Rural Hospitals
                            Please share with appropriate staff
From:                 Jacqueline Barton True | Vice President, Rural Health
                            jacquelineb@wsha.org | (206) 216-2541

Subject:            Home Health Shortage Area Declaration


This bulletin is to inform rural hospitals of recent changes to state law that will allow them to pursue designation as a home health shortage area. Declaration as a shortage area allows rural health clinics (RHCs) serving those areas to provide a limited scope of home health services, including visiting nurse services at the RHC encounter rate.


Senate Bill 6359 provides an exemption for RHCs in Department of Health (DOH) designated home health shortage areas from both licensing and Certificate of Need requirements for home health agencies. DOH is in the process of finalizing the elements by which rural hospitals and RHCs may apply for shortage area designation. Please see below for additional information regarding the application process.


Review the bulletin and share with appropriate staff. Hospitals interested in applying for shortage area designation should contact Pat Justis at the State Office of Rural Health.


Rural and remote areas of Washington State lack adequate access to home health services. Federal law allows RHCs to request designation of a home health shortage area by the Department of Health (DOH) with approval from CMS. More than 18 months ago, WSHA and its members engaged DOH and the Home Care Association of Washington to determine an application process that would allow RHCs to offer visiting nurse services in areas not adequately served by home health. WSHA then engaged in a legislative fix to help ensure access to these essential services. We were pleased the legislature enacted SB 6359 to remove state law barriers to that process.

CMS regulations in Chapter 2 446 CMS State Operations Manual allow Rural Health Clinics (RHC) to provide skilled nursing home visits if the patient meets the medical necessity and homebound status care standard required of home health agencies. The process for determining a shortage is delegated to the licensing and regulatory agency for the state and their proposed process to determine shortage areas must be approved by the CMS Regional Office.

If approved by DOH and CMS Region X, the RHC can offer home nursing visits by a registered nurse (RN) or a licensed practical nurse (LPN) to patients who meet CMS homebound definitions. For billing purposes, this service is an RHC encounter and does not allow for the full scope of home health, including physical therapy, occupational therapy, speech language pathology or medical social worker visits.
To be considered a shortage area, an RHC must demonstrate that they serve an area below the state median for home health services. The application process requires applicants to demonstrate:

  • Attestation of community problem solving (engagement with the home health agency that holds the certificate of need for that area;
  • Staffing plan;
  • Population to be served; and
  • Geographic area to be served.

Once approved by DOH, the RHC must then request designation from the CMS Region X office. Designations will be reviewed after a minimum of two years. Home Health Agencies with the certificate of need for the shortage area may request a review after one year.



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