Is your hospital considering an REH conversion?
Assessing the REH Conversion
What is a Rural Emergency Hospital?
How Can a Rural Emergency Hospital Designation Benefit Your Community?
Rural Emergency Hospital is a new Medicare provider designation designed to avert hospital closures and keep care in rural communities, providing the following benefits:
What are the REH Eligibility Requirements?
To qualify as an REH, the hospital must:
- Be in a rural area and licensed as a critical access hospital (CAH) or rural prospective payment system (PPS) hospital as of December 27, 2020, with fewer than 50 beds
- Be a licensed Medicare provider
- Meet staff training and certification requirements
- Meet annual average length of stay requirements*
- Have an established transfer agreement with a Level I or Level II trauma center
- Meet conditions of participation (similar to a CAH or PPS hospital for emergency services)
- Have an action plan including provisions for staffing, a transition plan, and a description of services offered
What is the REH Technical Assistance Center Approach?
Work cooperatively with HRSA, State Offices of Rural Health, and Flex Coordinators to identify interested hospitals
Respond quickly to direct inquiries made through our support line at REHsupport@rhrco.org
Protect the identity of each hospital organization we work with through an NDA
Provide a rurally relevant subject matter expert/coach to provide one-on-one guidance and support
Provide detailed financial modeling when there is an indication that the REH could be a viable option
Support strategic planning once a community identifies that REH is a viable path forward
Assist with the application and provide ongoing support
What Services Does RHRC Provide Throughout This Process?
Hospital Financial Analysis
Clinical Transformation / Value-based Transition Support
Strategic Planning
Organizational Culture Development
Legal Advice
Marketing Toolkit
Service Line and Outmigration Analysis
Leadership and Team Development
Regulatory and Compliance Support
Quality Performance Management
Data Analytics and Dashboards
What Are the Steps in the REH Conversion Process?
RHRC specialists work to make the REH conversion process seamless and swift.
Determine Eligibility
Determine whether the hospital meets REH requirements
Assess
Assess benefits and downsides to conversion:
• Financial analysis
• Service line analysis
• Outmigration reports
Consider operational and staffing changes needed
Apply
Submit application with required documentation (action plan, transfer agreement(s), COP attestation)
Convert
Implement operational and staffing changes
Address challenges of operational changes
Ongoing Support
Incorporate transformational systems that address ongoing challenges and build on strengths
Interested in Receiving Support from the Rural Emergency Hospital Technical Assistance Center?
Let us know by completing our brief intake form and telling us a little about your organization and the type(s) of support you are looking for.
If you have a question or would like to request more information, reach out to us directly at REHsupport@rhrco.org.
REH Frequently Asked Questions
A facility is eligible to enroll as an REH if it is a critical access hospital (CAH) or a rural hospital with 50 beds or fewer as of the date of enactment of the Consolidated Appropriations Act, December 27, 2020.ii
Financial or operational benefits from REH conversion are highly dependent on the hospital’s circumstances. Rural hospitals facing a high likelihood of closure may benefit from enhanced payments made available to REHs, which receive the Outpatient Prospective Payment System rate plus an additional 5 percent for REH-covered services. Non-REH services (such as laboratory and distinct part Skilled Nursing Facility services) are paid according to the facility’s respective fee schedule and do not qualify for the additional five percent payment. In addition, REHs will receive a monthly facility payment of $272,866 before sequestration in 2023, with annual increases determined by the hospital market basket. The hospital market basket adjustments are made on January 1 to align with the calendar year. REHs can also determine the appropriate licensure and credentials for a 24/7 staffed Emergency Department. Hospital leadership can elect to provide additional services that meet the community’s needs.
As the REH provider designation became active for Medicare on January 1, 2023, states have varied legislative and regulatory responses to recognizing the provider type. The National Conference of State Legislatures is currently tracking legislation and regulatory action in states related to REHs. To access the most recent information about state-level REH legislation, visit the Health Costs, Coverage and Delivery State Legislation database and filter on “Payment and Delivery Reform” under “Market” in the topic search section. You can also filter by state and status (as in, adopted, enacted, to the governor) of the legislation. For additional support related to state legislation: NASHP NACSL.
A hospital must meet all REH requirements and have been operating as a licensed hospital on the date the legislation passed allowing the new REH designation. Since the hospital closed before December 27, 2020, and was not functioning as a hospital as of that date, it is not currently eligible to be reopened as a licensed REH.
The enrollment process was simplified to allow existing hospitals and CAHs to submit the CMS-855A – change of information application to prevent closure of facilities that may disrupt services in the community. The hospital should submit its enrollment application prior to closure. If the hospital continues operating while the application is reviewed, it is eligible for the attestation of compliance. If the hospital closes before the REH designation, an on-site survey is required to ensure CoP compliance. More information is available in the Guidance for Rural Emergency Hospital Provisions, Conversion Process and Conditions of Participation memo.
The REH must maintain rural status or remain in an area designated or reclassified rural per 42 CFR §412.103. When an REH plans to relocate, it must update the CMS-855A form and submit it for reapproval. More information is available in the Guidance for Rural Emergency Hospital Provisions, Conversion Process and Conditions of Participation memo.
A facility is eligible to enroll as an REH if it is a critical access hospital (CAH) or a rural hospital with fifty beds or less as of
the date of enactment of the Consolidated Appropriations Act, December 27, 2020.2
Financial or operational benefits from REH conversion are highly dependent on the circumstances of the hospital. Rural hospitals facing a high likelihood of closure may benefit from enhanced payments made available to REHs. REHs will receive the Outpatient Prospective Payment System rate plus an additional 5 percent for REH-covered services. Non-REH services (such as laboratory, distinct part Skilled Nursing Facility services) are paid according to the facility’s respective fee schedule and do not qualify for the additional 5 percent payment. In addition, REHs will receive a monthly facility payment of $272,866 before sequestration in 2023, with annual increases determined by the hospital market basket. The hospital market basket adjustments are made January 1 to align with the calendar year.
REHs also have the flexibility to determine the appropriate licensure and credentials for a 24/7 staffed emergency department. Hospital leadership can elect to provide additional services that meet the needs of the community.
A hospital must meet all REH requirements and have been operating as a licensed hospital on the date the legislation passed allowing the new REH designation. As a result, since the hospital closed prior to December 27, 2020, and was not functioning as a hospital as of this date, it is not currently eligible to be reopened as a licensed REH.
The enrollment process was simplified to allow existing hospitals and CAHs to submit the CMS-855A – change of information application to prevent closure of facilities that may disrupt services in the community. The hospital should submit its enrollment application prior to closure. If the hospital continues operating while the application is reviewed, it is eligible for the attestation of compliance versus. If the hospital closes prior to the REH designation, an on-site survey to ensure CoP compliance is required. More information is available in the Guidance for Rural Emergency Hospital Provisions, Conversion Process and Conditions of Participation memo.
The application process for converting to an REH includes a change of information application – Form CMS-855A. An eligible hospital can apply – submitting the Form along with an action plan and a transfer agreement. The complete process for eligible facilities to convert to an REH is outlined in the Medicare Enrollment of Rural Emergency Hospitals3 and the Guidance for Rural Emergency Hospital Provisions, Conversion Process and Conditions of Participation memos.
For more commonly asked questions, please refer to this guide.
Our REH Footprint and Impact
The RHRC has been an invaluable partner and great help at this time. They have provided insight, instructions, professionals, support, you name it. Their work and commitment is totally different from any other advisor or consultant we have been able to hire. Their goal is our success, the same as ours; that is their difference between others we have hired.”
Carla Flack
Board Member, Bucktail Medical Center
REH Interest and Enrollment
Enrollment into our technical assistance process occurs on an ongoing basis and we encourage interested hospitals to reach out at any time. Our team is committed to meeting the urgency of your needs.