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Release of the REH designations for 2023, indicates that CMS will only be covering outpatient, emergency, and observation care services.

Last Tuesday, the U.S. Department of Health and Human Services (HHS) released new updates to address health equity by increasing rural care access.

A press release made official the earlier proposed place of service titled Rural Emergency Hospitals (REHs). This designation will allow Critical Access Hospitals (CAHs) and small rural hospitals the opportunity to convert to REHs. When I reported on this back in August, there was concern that the REH designation would not cover inpatient services.

This has been confirmed with the release of REH designations for 2023, as they would only be covering outpatient, emergency, and observation care services. Similar to other place-of-service designations, the REH requirements establish a full range of health and safety standards, including requirements for services offered, staffing, and physical environment and emergency preparedness.

More specifically, REHs require:

  1. A clinician on-call at all times and available on site within 30 or 60 minutes, depending on if the facility is located in a frontier area;
  2. 24/7 staffing to address emergency medical care with appropriate licensed professionals;
  3. Maintaining and submitting ongoing data requirements for Quality Assurance and Performance Improvement Program (QAPI);
  4. Annual per-patient average length of stay not to exceed 24 hours, and the time of calculation begins with registration check-in or triage and ends with the discharge time from the REH; and
  5. An infection prevention and control and antibiotic stewardship program.

Okay, well, this is what it is, and thus rural hospitals or CAHs will have to decide if it is worth switching to the REH designation.

Additionally, Medicare is expanding the promotion of hospital outpatient departments to reimburse for remote behavioral health services provided to people at home. The Centers for Medicare & Medicaid Services (CMS) first implemented this policy through emergency rulemaking in response to the COVID-19 public health emergency (PHE). CMS has now officially made this ruling permanent to ensure continued access to behavioral health services via telemedicine in hospital outpatient departments. This rule requires that beneficiaries receive an in-person service within six months prior to the first-time hospital clinical staff provision of behavioral health services remotely, and there must be an in-person service within 12 months of the behavioral health service being furnished remotely.

CMS is clarifying if audio-only communication can be used, if video and audio capabilities are not available for remote services. They have made the intention clear that they do not want to discourage availability of behavioral health access because of technology limitations; however, I would just suggest that in all cases, ensure there is proper documentation to cover how the remote service was provided and why the patient could not do video, should this be an issue.

Today I ask a generic question: is your hospital or health system ready for all the 2023 CMS changes? The responses may surprise you; they can be viewed here.

Programming Note: Listen to Tiffany Ferguson’s live reporting on the SDoH every Monday on Monitor Mondays at 10 a.m. EST.


Tiffany Ferguson, LMSW, CMAC, ACM

Tiffany Ferguson is CEO of Phoenix Medical Management, Inc., the care management company. Tiffany serves on the ACPA Observation Subcommittee. Tiffany is a contributor to RACmonitor, Case Management Monthly, and commentator for Finally Friday. After practicing as a hospital social worker, she went on to serve as Director of Case Management and quickly assumed responsibilities in system level leadership roles for Health and Care Management and c-level responsibility for a large employed medical group. Tiffany received her MSW at UCLA. She is a licensed social worker, ACM, and CMAC certified.

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