Recently, the OIG issued a report indicating approximately two-thirds of the critical access hospitals (CAH) would lose their CAH designation if necessary provider status was rescinded. Prior to January 1, 2006, a state could designate a hospital as a CAH based on specific criteria as well as meeting their Conditions of Participation, even if the CAH was within the 35-mile boundary in relation to another hospital. Since then, CMS released two transmittals to update and clarify certain sections of the CAH Conditions of Participation.
Transmittal 90 issues guidance on when a CAH qualifies for using the lesser 15-mile standard for minimum distance from another hospital or CAH based on the definition of mountainous terrain or the availability of secondary roads between hospitals. This transmittal also clarifies whether a CAH meets the rural location requirements based on its physical location or redesignation as rural based on certain criteria. Both of these verification criteria were effective August 30, 2013, and should be reviewed by CAHs that fall under the distance exemption or rural reclassification.
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