CMS releases guidance on REH enrollment, conversion

Wednesday, February 8, 2023

CMS recently released guidance and FAQs on the newest Medicare provider type, rural emergency hospitals (REH). The January 26 guidance focused on the enrollment and conversion process for eligible hospitals looking to participate in Medicare programs as an REH.

According to CMS, eligible facilities include critical access hospitals (CAH) or rural hospitals with no more than 50 beds as of December 27, 2020. Facilities that meet these requirements but closed after that date are also eligible.

The guidelines state that eligible facilities must submit a CMS-855A change of information application, rather than an initial enrollment application, to their designated Medicare Administrator Contractor to enroll as an REH.

In addition to a change of information application, eligible facilities must submit an action plan for initiating REH services to their designated state agency. The action plan must outline how the facility plans to convert to an REH and how it will launch REH-specific services, according to CMS’ guidance.

A facility’s plan should also include staffing provisions and a list of the specific services it will retain, modify, add, and discontinue.

After converting to an REH, a facility can offer emergency department services and observation care and may also opt to provide additional outpatient services. Services cannot exceed an annual per-patient average length of stay of 24 hours, according to CMS. REHs are not permitted to provide inpatient services unless those services are provided on a unit that’s a distinct part licensed as a skilled nursing facility.

The REH was first established as a provider type in the Consolidated Appropriations Act of 2021. CMS detailed the REH Conditions of Participation (CoPs) in the 2023 Outpatient Prospective Payment System (OPPS) final rule. In its recent guidance, CMS said that REH standards account for the provider type’s “uniqueness,” but generally align with CAH CoPs.

CMS said it intends to provide interpretive guidance on REHs in the future. Facilities that are interested in converting to an REH should stay up to date on any related information. Revenue integrity professionals in rural facilities should review this latest guidance and the 2023 OPPS final rule to determine eligibility, project the financial impact of converting, and ensure compliance.

Editor’s note: Find more NAHRI resources for rural facilities here.

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