NARHC-News | Winter 2020
RHC Articles in This Newsletter

• RHCs Excluded from Principal Care Mgm Benefit
• New Medicare Mandate: Appropriate Use Criteria
• Update from NARHC's Education Committee
• Introduction to RHCs Online Course
• RHC Cap Raised Slightly
• Next Session: CRHCP
• 2020 NARHC Spring Institute
• Free Webinar Series: Everyone's a Caregiver
• Trump Administration Lowers Rx Drug Prices
• Most HICN Claims Reject
• 3 Facts About Veterans
• Patients Over Paperwork
• Federal Court Strikes Down ACA Key Part
• The Final Rule
• Received a Survey Deficiency? What Now?
RHCs Excluded from Principal Care Management Benefit in 2020
Conflicting Statements from CMS in 2020 Final Rule

In 2020, Rural Health Clinics may not bill for Principal Care Management. Principal Care Management (PCM) is a new benefit that Medicare will cover in 2020. It is very similar to the chronic care management (CCM) benefit, except for the fact that patients can qualify for principal care management services with only one chronic condition, whereas CCM services can only be provided to patients with at least two chronic conditions.

The 2020 Medicare Physician Fee Schedule contained conflicting language that at one point stated that rural health clinics could bill for PCM services using our CCM or “care management” G-code G0511, and then at another point stated that RHCs could not bill for PCM. NARHC and others pointed out these conflicting sections to CMS and they issued a correction on January 2nd which clarified that RHCs may not bill for Principal Care Management with our G0511 code or any other code.    Read More
New Medicare Mandate: Appropriate Use Criteria
Affects Orders for Advanced Imaging

This year, you may begin hearing from the imaging departments or imaging facilities in your area about something called the “Appropriate Use Criteria” or clinical decision support mandate. Imaging centers may begin asking for or requiring that you provide them with additional information before they can move forward with an advanced image on your Medicare patients.

What is the Appropriate Use Criteria (AUC) Mandate?

The appropriate use criteria mandate is a Medicare program (which Congress created in 2014) designed to ensure that orders of advanced imaging are appropriate given the clinical condition of the patient. Any time a RHC clinician orders an advanced image (MRI, CT scan, nuclear medicine, or PET scan), the clinician must verify that this advanced image order is in fact necessary and proper.  Read More
Update from NARHC's Education Committee

Greetings to all in the New Year! Looks like we have plenty ahead of us in the Rural Health Clinics world. The Education Committee was recently organized by your Board of Directors to focus on the association’s ongoing efforts to deliver the highest quality, most current and relevant material to our members. With that direction the education committee has taken to task two specific areas. 

The first has recently been released and you can read more about it on the Events tab of the NARHC website or in the next article. This course is a basic introduction to how a RHC differs from a traditional medical practice and is designed for new members of your office team. We think you will be impressed.

Our second project is the continuing refinement of the CRHCP certification course and the maintenance of that certification.     Read More
Introduction to RHCs Online Course
Registration Now Open!

NARHC is proud to announce the launch of a new orientation tool. It's just 1-hour long and is FREE to NARHC members!

Geared toward employees new to the RHC world, the course covers the basic fundamentals of running an RHC, how RHCs differ from other types of clinical offices, a brief history of the RHC program, and how NARHC was formed. Th e online course consists of 4 short modules. Most individuals will finish the course in no more than one hour. 

The Intro Course is offered FREE to employees of a clinic with a current NARHC Membership. If you do not have a current membership you can Become A Member , or you have the option to purchase the course for $50 per individual. Please register online HERE . If you have any questions please contact staff at  
RHC Cap Raised Slightly to $86.31
No Longer Covering Costs for Most RHCs

The RHC cap will be $86.31 in 2020. This is up 1.9 percent from $84.70 in 2019. Read More
Stay Informed & Help Others Discover NARHC...
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Next Session of NARHC's...
 Certified RHC Professional Course (CRHCP)
In-Person Final Exam in San Antonio on March 20, 2020
Registration Now Open!

ONLINE TRAINING* will prepare you to successfully manage & run an RHC. Learn the latest information on RHC rules, regulations, and laws. Study nights, weekends, or whenever your schedule permits! Course takes approximately 30 hours. No prerequisite! Coursework is broken into 3 modules with video presentations & a series of short knowledge-based tests for each module. This course is designed to give you a well-rounded, ground level knowledge base of the major facets of RHC management. Those who pass the final test will receive the CRHCP certification (behind their name)! Read More

  • Module 1: Administration & Finance
  • Module 2: Billing & Coding
  • Module 3: Regulatory Compliance & Quality
Early Bird Price only through Feb. 3...
2020 NARHC Spring Institute
Hyatt Regency Riverwalk, San Antonio, Texas
March 18-20, 2020   (W-F noon)   

The conference "for & about" RHCs -- 22 Speakers, 17 Sessions. Members save $100-$125
  • RHC Basics + Billing 101
  • RHC Cost Reporting 101
  • RHC Compliance 101 + 201
  • Washington Update
  • Growing Your RHC
  • Creating an Opioid Treatment Program in Your RHC
  • Managing Multi-Generations in the Workplace
  • Managing a Multi-Chain Health System
  • RHC Advanced Billing
  • Advanced Cost Reports
  • Policies & Procedures
  • Leadership Self Care
  • Quality Reporting & Care Management in RHCs
  • Lessons Learned from Clinic Managers
  • Critical Maintenance of Emergency Plan Biennial Review, Civil Rights, Personnel File Audits
  • Novitas Session    
Free Webinar Series
Everyone's a Caregiver ®   Mastery Series Patient Centered Clinic

Educate, engage and empower everyone to provide a world class, compassionate patient experience in a series of approx. 30 minute webinars-one a month for 8 months. It includes 50 Patient Experience Skills:

  • 10 Getting Timely Access (1 webinar)
  • 22 Responsive, Helpful Office Staff (3 webinars)
  • 13 Physician/Provider Communication & Overall Rating (2 webinars)
  • 5 Care Coordination/Follow-up (2 webinars)
  • 8 high impact webinars presented by acclaimed authors

The series is relevant for Physicians, Advanced Care Practitioners, Medical Office Staff, Nurses & Clinic Management. Webinars are on the 2nd or 3rd Wednesday of the month at these times: 10 PT / 11 MT / 12 CT / 1 ET. The Series starts Jan. 15, 2020. If you miss a webinar, you can still access the Series most recent videos for a full week following the premiere of that webinar. Brought to you by NARHC sponsor Custom Learning Systems. Registration info. follows but to see descriptions of webinars Read More

To Register: Click Here
Sponsor Code: P2_NARHC
*If registering for multiple webinars, please enter ALL sponsor codes at the same time .
Trump Administration Takes Historic Steps to Lower U.S. Prescription Drug Prices

Proposed rule could allow certain prescription drugs to be imported from Canada; draft guidance explains how manufacturers could import drugs, biological products originally intended for sale in another country

On Dec. 18, President Trump, along with the U.S. Department of Health and Human Services and the U.S. Food and Drug Administration, issued a notice of proposed rulemaking (NPRM) that, if finalized, would allow for the importation of certain prescription drugs from Canada. In addition, the Administration is announcing the availability of a new draft guidance for industry that describes procedures drug manufacturers can follow to facilitate importation of prescription drugs, including biological products, that are FDA-approved, manufactured abroad, authorized for sale in any foreign country & originally intended for sale in that foreign country. Read More
Most HICN Claims Reject  –  Regardless of Date of Service

Use Medicare Beneficiary Identifiers (MBIs) now to avoid claim and eligibility transaction rejects. Effective January 1, 2020, regardless of the date of service on the Medicare transaction, most Social Security Number – based Health Insurance Claim Number (HICN) Medicare transactions will reject with a few exceptions.

If you do not use MBIs on claims after January 1, you will get:

  • Electronic claims reject codes: Claims Status Category Code of A7 (acknowledgment rejected for invalid information), a Claims Status Code of 164 (entity’s contract/member number), and an Entity Code of IL (subscriber)
  • Paper claims notices: Claim Adjustment Reason Code (CARC) 16 “Claim/service lacks information or has submission/billing error(s)” and Remittance Advice Remark Code (RARC) N382 “Missing/incomplete/invalid patient identifier” 
3 Facts About Veterans

Providers working with Veterans who are at risk of suicide want to ensure they are utilizing the best approaches to caring for those Veterans. If you are one of these providers, the U.S. Department of Veterans’ Affairs (VA) Suicide Risk Management Consultation Program (SRM) is available to support you as you navigate scenarios that can sometimes be complex or stressful. Here are some important facts about Veterans. 

  1. Prevalence of Suicide is Higher among Veterans

Approximately 20 Veterans die by suicide every day, & most of those Veterans are not receiving care from the Veterans’ Health Administration (VHA). Read More
Patients Over Paperwork
Feedback on Scope of Practice

The Centers for Medicare & Medicaid Services (CMS) is seeking additional input and recommendations regarding elimination of specific Medicare regulations that require more stringent supervision than existing state scope of practice laws, or that limit health professionals from practicing at the top of their license.

We are seeking additional feedback in response to part of the President’s Executive Order (EO) #13890 on Protecting and Improving Medicare for Our Nation’s Seniors. The EO specifically directs HHS to propose a number of reforms to the Medicare program, including ones that eliminate supervision and licensure requirements of the Medicare program that are more stringent than other applicable federal or state laws. Read More
Federal Appeals Court Strikes Down Key Part of the ACA

Dec. 19, 2019—A federal appeals court in New Orleans struck down a major part of the Affordable Care Act, a decision that eventually could jeopardize health insurance for millions of Americans and set up an election-year showdown at the Supreme Court. Read More

The Final Rule
Patient Policies, Program Evaluations, Emergency Preparation

The new final rule does the following:

  • Changes the Policy Review and Annual Evaluations to biennial requirements.
  • Changes requirement for facilities to review emergency preparedness program to biennial.
  • Eliminates the need to document outreach efforts to local emergency resources, but facilities will “still be required to include a process for cooperation and collaboration” with them.
  • Requires facilities to provide training biennially or every 2 years, after facilities conduct initial training on their emergency program.
Received a Survey Deficiency? What Now?
How to Write a Successful Plan of Correction

  1. Respond promptly. A Plan of Correction is due ten (10) calendar days from when the statement of deficiency is received. Respond promptly. Follow any directions which came with the SOD. Ask questions or get clarification if you are unsure about anything. If you are in a state that also has a licensing survey, more than one POC may be required—one for the CMS deficiencies and one for the state deficiencies. 
  2. Be Objective. Your response should clearly state your plan of correction. This is NOT the time or place to defend your own actions or to criticize the surveyor. Do not try to justify what you did or didn’t do. Stick to the facts. Be concise. Be realistic. Focus on clear corrective actions & ongoing compliance. 
NARHC members may contribute articles to the quarterly NARHC-news.
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National Association of Rural Health Clinics | NARHC | Ph. 866-306-1961 | Fax 866-311-9606
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