- CAHs are billing Medicare and beneficiaries according to Medicare rules and regulations, any deviance from these guidelines would result in fines and penalties resulting from non-compliant billing.
- Medicare can correct this policy very simply by holding harmless beneficiaries on coinsurance calculations between CAH and PPS hospitals. This change would increase Medicare payments to CAHs in order ensure that CAHs receive 101 percent of cost.
- NRHA disagrees with OIG’s assertion that CAH participation in a possible fix be contingent upon re-certifying their CAH status. All CAHs were designated according to rules and regulations in place at varying points in time historically. The Necessary Provider program allowed for a state’s right to designate hospitals it deemed essential according to an overall rural health plan. These rural health plans were approved, in turn, by CMS. All CAHs should be fully reimbursed at 101 percent of their cost if a coinsurance change is implemented.
- NRHA believes that the current CMS policy unfairly penalizes rural patients, which is not the intent of Congress. We ask Congress to direct CMS to not shift the burden to providers or to patients.
CRHC will continue to monitor this issue and keep you up to date. If you have any questions or feedback, please contact Michelle Mills, mm@coruralhealth.org or Jen Dunn, jd@coruralhealth.org.