NARHC Policy and Advocacy
NARHC’s policy and advocacy efforts advance the NARHC mission, enhancing the ability of RHCs to deliver cost-effective, quality health care to patients in rural, underserved communities. NARHC’s government affairs team, based in Washington, D.C. serves as the primary resource to Congress, federal agencies, and the Administration on federal Rural Health Clinic issues.
Together with the NARHC Policy Committee, we focus on both regulatory and legislative options to increase access to care, remove unnecessary regulatory burdens, protect the integrity of the RHC program, and enhance reimbursement policies that incentivize and support rural, outpatient health care services. Advocacy and comment letters sent to CMS, HHS, and Members of Congress can be found here.
Our team develops policy priorities and strategies to accomplish these priorities. Additionally, we develop materials intended to engage RHCs in federal advocacy efforts. For more details on how to make your voice heard or with any questions, please email Sarah Hohman, NARHC Director of Government Affairs, at Sarah.Hohman@narhc.org.
NARHC 2025/2026 Policy Priorities
1. Telehealth
Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19, both policy unique to RHCs and more broadly within the fee-for-service community. Current telehealth flexibilities for all providers are set to expire September 30th, 2025 without Congressional action.
Simply extending the current temporary policy on September 30th will perpetuate the “special payment rule” that significantly disadvantages RHCs hoping to invest in telehealth. NARHC continues to advocate for permanent coverage of all telehealth services but with a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.
NARHC also advocates for updated billing codes that would grant access to data on telehealth services utilized by RHCs. Currently, all 220+ services are billed under a single code, preventing any collection of data about which services are used most by the RHC community.
NARHC is awaiting reintroduction of several pieces of legislation from the 118th Congress that addressed RHC telehealth policy fixes.
For details on billing for telehealth and related services, as well as to help us advocate on this issue,please visit NARHC’s Telehealth Policy page.
Good Faith Estimate (GFE) requirements, enacted through the No Surprises Act, requires that RHCs, and all providers, issue a GFE to all uninsured or self-pay patients upon request, and when they schedule an appointment 3+ days in advance. Please visit our Good Faith Estimate Resources for more information and details regarding compliance.
While NARHC is supportive of efforts to increase price transparency for patients, we have requested that CMS engage further with providers and other stakeholders on price transparency policies that achieve these goals without adding so much complexity and cost to the scheduling process. In response to stakeholder feedback, CMS did delay Phase II of the policy, pending future rulemaking. NARHC will remain engaged on this issue.
3. Medicare Advantage
Medicare Advantage enrollment has surpassed traditional Medicare enrollment amongst eligible beneficiaries. While RHCs receive enhanced traditional Medicare payments in comparison with their fee-for-service counterparts, there is no statutory requirement around RHC Medicare Advantage reimbursement and RHCs will be paid the contracted amount they have negotiated with each individual MA plan. Comparatively, FQHCs are eligible for “wrap payments”, through which Medicare will pay the difference if Medicare Advantage plans reimburse less than the Medicare PPS rate. NARHC supports RHC “wrap payments” similar to the FQHC model, or a reimbursement floor for MA plans similar to traditional Medicare reimbursements.
NARHC is currently securing MA champions to introduce a bill addressing the issues above.
4. Value-Based/Quality Reporting for RHCs
NARHC supports the establishment of a quality reporting program designed for RHCs. It is imperative that such a program be made available to all RHCs. RHC participation in quality programs could be greatly increased and improved if a quality payment program specifically for RHCs was created. Because the RHC payment structure is essential to the RHC program but also quite different from FFS payment, the best way to bring value into the RHC model is to design a program solely for RHCs.
5. Medicaid
RHCs rely on enhanced Medicaid reimbursements to provide care for their community. They do not receive any funding to provide care for uninsured patients and are not eligible for any 330 grants. 30% of RHC patients are insured by Medicaid, and cuts to the program could take away their access to healthcare entirely. NARHC remains engaged in Medicaid discussions to emphasize the significant damage program cuts will have on RHCs.
Other Rural Health Legislation
So far in the 119th Congress, several rural health related bills have been introduced with bipartisan support. NARHC is supportive of these efforts to increase access to quality health care to patients in rural America and will continue to monitor this legislation. This may not be an exhaustive list of all bills supported by NARHC. With any questions about these bills or others, please contact Sarah.Hohman@narhc.org.
- Strengthening Pathways to Health Professions Act (H.R.593)
- Provides tax relief for certain health professional scholarships and loan payments intended to increase availability of health care services in underserved or health professional shortage areas.
- Rural Health Care Access Act of 2025 (H.R.771)
- Removes the requirement that prevents hospitals from pursuing a Critical Access Hospital (CAH) designation if it falls within 35-miles of another CAH.
- Improving Care and Access to Nurses Act (H.R.1317)
- Under Medicare and Medicaid, this act removes various barriers to practice for several RHC professionals, including NPs, certified nurse-midwives, and advanced practice registered nurses.
- Under Medicare and Medicaid, this act removes various barriers to practice for several RHC professionals, including NPs, certified nurse-midwives, and advanced practice registered nurses.
