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CHA has submitted comments on the proposed conditions of participation (CoPs) for the new rural emergency hospital (REH) provider type and updated CoPs for critical access hospitals (CAHs) issued by the Centers for Medicare & Medicaid Services (CMS).
In the letter, while CHA believes the proposed clarified definition of “primary road” used to calculate the CAH distance requirements is an improvement over the definition in the State Operations Manual, CHA requested further clarification on the road requirements for purposes of determining a hospital’s eligibility for critical access status.
Additionally, CHA asked CMS to develop a process to grandfather in existing CAHs that lose their status as a result of the new “primary road” definition if they are located in a state that does not allow for licensure of REHs. CHA supported CMS’ proposal to allow CAHs that are part of a larger organization to meet the requirements of the CoPs if they participate in the system’s unified or integrated structure.
