December 9, 2023

So in terms of next steps, Maya, when it comes to rolling out this rural emergency hospital model, what does that look like? How do you think it will be received? I imagine rural hospitals have to start preparing now to convert, you know, which comes with an additional expense and time and so on so forth.

Maya Goldman:Well, the immediate next step would be the comment period on the rule. So any member of the public can voice their opinions on these proposals to CMS up until September 13. And then the agency will finalize the role probably sometime in late October, we’ll have to see if CMS makes any big changes to the policy. And then payment should begin January 1, 2023, for rural emergency hospitals. From what I’ve heard and read and what you’ve talked about, rural hospitals aren’t all very excited about the model. So I expect that to show up in the comments. But I’m not sure how much CMS can change since this new model was created through legislation. So they’re sort of beholden to what was in the law. But it will be interesting to follow this and to see what if anything does change from the proposed rule to the final rule of speaking of changes in policy.

Alex, what other policy changes could help sustain rural hospitals aside from this new model?

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Alex Kacik: Sure. I’ve heard a few suggestions here. As for maternity care, midwives, and doulas can help fill some of the gaps outside of the hospital setting. But they are limited by scope of practice laws. So those may need some tweaking. And then that is also always tricky, because you typically need some legislation to change that. The federal government could expand the National Health Services Corps funding for midwives, the program that incentivizes tuition reimbursement for caregivers, entering underserved areas. Another suggestion involves paying higher reimbursement rates to low volume obstetric units that are more expensive to maintain.

That last one I thought was interesting. I didn’t know how feasible it was to set up like a sliding scale of sorts when it comes to reimbursement.

Would it be feasible to set up a flexible payment rate via Medicare, Medicaid to rural hospitals based on their annual procedure volumes?

Maya Goldman: That is a great question and If any listeners out there want to let us know what you think we would love to hear your thoughts.

I don’t know where efforts stand around different payment based on procedure volumes. But this certainly seems like an area where maybe the Center for Medicare and Medicaid Innovation could jump in with an alternative payment model. I know CMS is working to bring more rural providers into value-based care in general, and alternative payment in general and several changes to the Medicare Shared Savings Program, which is the largest ACO, Accountable Care Organization program that CMS runs. The proposed changes from earlier this month for that program are also aimed at bringing in rural providers and other providers into the program. And they include policies like upfront payments to help with startup costs and longer periods to ease into downside risk arrangements. So I could expect that we could see some more innovation in that area coming up.

Read more:
Q&A with Elizabeth Fowler of the Center for Medicare and Medicaid Innovation: ‘We want to be a good partner to good actors’
The Check Up: Elizabeth Fowler of Center for Medicare and Medicaid Innovation

Alex Kacik: Well, this gives us a lot to follow up on Maya. Thank you so much for sharing your reporting expertise with us.

Maya Goldman:Thank you for having me, Alex. Always great to talk.

Alex Kacik: And thank you all for listening. You can subscribe to Beyond the Byline on Spotify, Apple podcasts or wherever you choose to listen. You can support the reporting of Maya, myself and our team of reporters by subscribing to Modern Healthcare and giving us a follow on Twitter and LinkedIn. Thank you for your support.

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