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NRHA Regulatory Comment Letter Update

NRHA frequently comments on proposed regulations impacting rural health to ensure that the impact of new regulatory requirements on rural providers is considered in the process. We recently posted the latest regulatory comment letters, written by NRHA’s Regulatory Counsel Diane Calmus, on ruralhealthweb.org. Members are encouraged to read the letters and reach out with any questions.

Promoting Telehealth for Low-Income Consumers: Promoting Telehealth for Low-Income Consumers, Notice of Inquiry – WC Docket No 18-213. 
  • As NRHA reported last week, the Federal Communications Commission (FCC) has voted to approve a Connected Care Pilot Program, a project focused on expanding telehealth and telemonitoring services outside the brick and mortar of a doctor’s office to low-income rural Americans.
  • NRHA encouraged the FCC to design the program with flexibility to allow rural communities to gain the maximum benefit while building a base of evidence to prove the efficacy of telemonitoring programs.

HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs: RIN 0991-ZA49 – Comments on HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs.
  • NRHA recently sent comments directed to Department of Health and Human Services (HHS) Secretary Alex Azar on the President’s proposed plan to lower drug prices.
  • NRHA urges cautious examination of unintended consequences of the proposed plan. For example, the push for site neutral payments for Part B drugs is essentially a simple rural hospital cuts where alternative sites for administration are unavailable. A particular concern at a time of rural hospital closures resulting from the plethora of rural hospital cuts, both implicit and explicit.
  • The 340B Program is an essential part of ensuring the continued existence of the rural safety net and is not a driver of high drug costs. As a direct result of the 340B program, rural hospitals have been able to continue to serve their communities despite continuous reimbursement cuts. NRHA encouraged CMS to keep regulatory burdens low in the 340B program to allow more of the proceeds from the program to go to patient care, in line with the CMS moves for reducing regulatory burden.

IPPS Rule and FY19 Rates: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and FY19 Rates
  • NRHA applauded the changes to the low-volume adjustment changes. However, we are concerned about the reweighting of the DRGs, which results in an implicit cut to rural hospitals. Furthermore, NRHA flagged concerns about the changes to policies regarding multi-campus hospitals to ensure the policy would not be interpreted to harm rural hospitals. Additionally, we expressed concern about the application of a national rural floor for the wage index, a policy CMS concedes will harm rural hospitals.
  • NRHA supports the goals of interoperability, but with the burden of compliance on the software companies instead of hospitals. NRHA vociferously opposed adding interoperability requirements to the Conditions of Participation (COP).

Traumatic Brain Injury Disparities in Rural Areas: Traumatic Brain Injury Disparities in Rural Areas (TBIDRA) - 83 Fed. Reg, 26464 (July 7, 2018)/Docket No. CDC-2018-0052
  • As rural health disparities continue to grow, NRHA appreciates the work of the CDC in undertaking a study of rural specific traumatic brain injury (TBI). As CDC completes the study, we urge that they include a variety of different communities, including ones that have lost their hospital or are in danger of the local hospital closing. Each rural area is different and unique with a varied mix of likely sources of TBI and different types of providers of care. Including this variety will provide a better understanding of care for TBI in rural America, including the various types of challenges in accessing care.

As various agencies continue to work to improve our health care system, we ask that any rules or regulations take into consideration the unique challenges facing rural providers, and the opportunities that can be created through flexible and stabilizing policies. Applying a rural lens, such as CMS has promised to do with its Rural Health Strategy, can help to create a healthy and strong future for rural America.

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