CMS Publishes Annual Proposed Rules with Significant RHC Provisions
Sarah Hohman, Director of Government Affairs
This afternoon, the Centers for Medicare and Medicaid Services (CMS) released the 2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule.
As a reminder, this annual rule provides regulatory updates to the fee schedule and also contains a significant section specifically for RHCs. We will be analyzing all of these RHC and related provisions and providing a full summary over the next few weeks! NARHC will later submit comments on behalf of the RHC community. If finalized, these changes would go into effect January 1, 2025.
For a brief overview of what this proposed rule for RHCs, please see the list below.
2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule
- Proposal to eliminate productivity standards
- Proposal to remove Hemoglobin / Hematocrit from the six required lab services
- Proposal for RHCs to bill HCPCS care management codes, instead of G0511
- Proposal to allow RHCs to bill for administration of part B preventive vaccines at time of service (if finalized, would begin July 1, 2025)
- Proposal to still require provision of primary care services but no longer enforce “primarily engaged in furnishing primary care services”
- Maintains that RHCs cannot be "primarily engaged in the treatment of mental diseases," but seeks comment on how to define "mental diseases"
- And more!
In addition to providing complete summaries, NARHC DC staff will be hosting an August webinar on all of these provisions to ensure that the RHC community is able to fully understand the proposed rules and provide any feedback to guide our formal comments to CMS.
Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule
In a busy regulatory week, CMS also released the Hospital Outpatient Prospective Payment System (OPPS) proposed rule. While there are no specific provisions for RHCs, there are several mentions of rural and provisions for Critical Access Hospitals (CAHs) and Rural Emergency Hospitals (REHs).
- Proposes REH quality reporting program
- Proposes new Conditions of Participation (CoPs) for CAHs and other hospitals for obstetrical services, such as staff training, quality assessment and performance improvement, and standards for staffing, delivery of care, etc.
Hospitals interested in learning more about these provisions can review the CMS OPPS Fact Sheet.
If you have any questions, please email Sarah.Hohman@narhc.org.
