NARHC-News | Winter 2021
RHC Articles in This Newsletter
• RHC Modernization in COVID Package
• NARHC Hosts Modernization Policy Webinar
• NARHC Letter to Congressional Staff
• COVID-19 Vaccine Info. Billing & Leftovers
• Upcoming FREE T.A. Webinars
• NARHC 2021 Virtual Spring Institute
• CRHCP Course 2021 Spring Session
RHC All Inclusive Rate (AIR) Payment Limit
How COVID Has Changed Healthcare HR
• How Long Does It Take to Become Immune
• RHC COVID-19 Testing Program
• Provider Relief Fund Reporting Update
• Understanding the 2021 Coding Changes
• The Value of Becoming PCMH
RHC Modernization Included in Final COVID Package

NARHC is pleased to report that Medicare reimbursement for RHCs will undergo a massive overhaul as part of the year-end COVID-19 relief & appropriations package passed by Congress. Notably, the RHC cap will be raised to $100 on April 1, 2021 & then the cap will gradually rise each year to $190 in 2028.

“Raising the cap has been the legislative priority of NARHC for over a decade,” said Bill Finerfrock, Executive Director of NARHC “we are ecstatic to see that Congress has opted to raise the cap for RHCs in this legislation.” Senator Chuck Grassley (R-IA), Chair of the Senate Finance Committee, played an instrumental role at getting the RHC modernization language into the final package. “I can confidently say without Senator Grassley’s leadership, this would not have gotten done.” Finerfrock said.

All newly established RHCs would now also be subject to this increased cap, which means that no new RHC (even those purchased or established by hospitals with less than 50 beds) could receive uncapped cost-based reimbursement.

Uncapped RHCs in existence today would be grandfathered-in at their current All-Inclusive Rate and would still see year-over-year increases but would be constrained to their current AIR plus an adjustment for MEI (the Medicare Economic Index).

Notably, the changes ensure that no RHC sees a reduction in Medicare reimbursement. “When the President’s Budget included a proposal that put all RHCs on a single PPS rate, we were concerned that many provider-based RHCs would see massive declines in their Medicare reimbursement.” Finerfrock said. “That is why we strongly advocated for a grandfathering provision to ensure that RHCs did not see any year-over-year declines in their Medicare reimbursement.”  Read More
NARHC Hosts Webinar on Modernization Policy
Webinar Covers Medicare Reimbursement Details

As part of H.R. 133, the Consolidated Appropriations Act of 2021 (aka COVID Relief Package), Congress approved and the President signed into law the most comprehensive reforms of the Medicare RHC payment methodology since the mid-90s. In this webinar, Bill Finerfrock, the Executive Director of NARHC, and Nathan Baugh, the Director of Government Affairs for NARHC, discuss these major changes in detail.

You can find slides & recording here. Read More
NARHC Letter to Congressional Staff
Issues with the RHC Modernization Policy

On January 15, 2021, NARHC sent the following message to Hill staff on some of the issues with the RHC Modernization Policy passed in the COVID Relief Package. Read More
COVID-19 Vaccine Information
Billing & Distribution of Leftover Vaccines

How do RHCs bill for COVID-19 Vaccine Administration?
RHCs will be reimbursed by Medicare for COVID-19 vaccine administration the same way we are reimbursed for flu and pneumococcal shots: a lump sum payment, based on vaccine administration costs as reported on the cost report. NARHC has confirmed that reimbursement for vaccine administration to patients with Medicare Advantage will be treated the same way as traditional Medicare beneficiaries, meaning that RHCs will not bill for the vaccine administration for any Medicare patient but rather capture the costs of such vaccinations on their cost report.

In January, CMS provided some guidance on this issue here:

From CMS:

  • COVID-19 Vaccines in RHCs and FQHCs - COVID-19 vaccines and their administration will be paid the same way influenza and pneumococcal vaccines and their administration are paid in RHCs and FQHCs. Influenza and pneumococcal vaccines and their administration are paid at 100 percent of reasonable cost through the cost report. The beneficiary coinsurance and deductible are waived. For additional information, please see

What should providers do if they have more vaccine supply than demand?   Read More
Upcoming FREE Technical Assistance Webinars

One of the many ways NARHC keeps you informed of regulative changes that affect rural health clinics is through our Technical Assistance webinars periodically throughout the year. These T.A. webinars are offered FREE of charge and are available to both members and non-members alike. We email upcoming webinars to those who have created a person profile on the NARHC website. Here are a few of the upcoming webinars…

  • New HIPAA Privacy Rule: What RHCs Need to Know – Jan. 27, 2021, 2:00 p.m. (Eastern), Speaker Sarah Badahman, CHPSE, Founder/Owner, HIPAAtrek. Register here:

  • HPSA 101 for RHCs – Feb. 2, 2021, 1:00 p.m. (Eastern), Speaker Dr. Janelle McCutchen, Chief, Shortage Designation Branch, Bureau of Health Workforce. Register here:

The series is produced by the Federal Office of Rural Health Policy (FORHP) in conjunction with the National Association of Rural Health Clinics (NARHC). Read More
Register Now for the
NARHC 2021 Virtual Spr. Institute

15 sessions, 14 speakers
Tues. & Thurs. afternoons April 13-27, 2021
Sessions live & recorded for later viewing 
CEUs tbd (usually AAPC, AAFP)

  • Washington Update
  • RHC COVID-19 Reporting Data & Vaccine Updates
  • RHC COVID-19 Reimbursement Impact Considerations
  • Practice Manager Survival Guide Amid COVID-19
  • RHC Billing & Cost Reporting
  • Techniques for Managing Continuous Change
  • Staying Compliant During COVID-19
  • Service Line Options in the RHC
  • Infection Control During COVID-19
  • Update to RHC Telehealth Services
  • Emergency Preparedness in the Midst of an Emergency
  • Understanding the 2021 Changes to E&M Coding
  • HIPAA Doesn't Go Away During a Pandemic
  • Human Resources in the RHC
CRHCP Course 2021 Spring Session
Registration Opens Feb. 2
In-Depth Overview of Managing an RHC

NARHC offers Directors, Clinic Administrators and other RHC leaders a unique, full-spectrum course designed to teach you how to operate a successful RHC. Since opening the course we have certified over 450 people with a 97% passing rate.

Cost: NARHC Members $450, Non-Members $600 (includes the final exam testing fee). For more information  Read More
CMS Announced
RHC All Inclusive Rate (AIR) Payment Limit
Calendar Year 2021 - $87.52 Read More
How COVID has Changed Healthcare HR and the Workforce

2020 has done more than impact the delivery of healthcare to patients. It has drastically changed how healthcare employees find jobs, protect themselves, balance work-life duties, and care for anyone and everyone who is sick.

COVID-19 has also forced profound changes for healthcare human resources professionals as they strategize and execute the core functions of successful HR programs. Because of new demands on the healthcare professionals who provide care, the future of healthcare HR must stay focused on three guiding principles: Invest in people; make talent retention and acquisition a top priority; and create a new future based on the reality that things will not return any time soon to a pre-pandemic normal. Read More
How Long Does It Take to Become Immune After You Get the Covid Vaccine
Here's What to Know

After a month of fits and starts, state and local governments across the U.S. are slowly ramping up distribution of COVID-19 vaccines. Health care workers and nursing home residents were the first to roll up their sleeves for a dose.

But as more people become eligible for a vaccine, there is still some confusion about how much protection it gives early on, as well as when people will be at peak immunity from COVID-19. Here, infectious disease clinical researcher Laurel Bristow clarifies the process. Read More
RHC COVID-19 Testing Program

This is a friendly reporting reminder for the RHC COVID-19 Testing Program. All RHCs funded in May and December 2020 must continue to report COVID-19 tests and spending categories monthly on the Rural Health Clinic COVID-19 Reporting Portal (Table 1). December data is due by January 31.
Thank you for all of your hard work thus far. We recognize RHCs face increased workload demands during the COVID-19 pandemic and appreciate your effort and diligence reporting your monthly data.
Table 1 RHC Reporting Deadlines

Monthly Data Reporting Deadline Applicable RHCS Reporting Details
December 2020 January 31, 2021 All RHCs funded in May and December 2020
January 2021 February 28, 2021 All RHCs funded in May and December 2020

HRSA has funded the National Association of Rural Health Clinics (NARHC) to provide technical assistance to RHCs on the RHC COVID-19 Testing Program. As part of the cooperative agreement, NARHC developed the RHC COVID-19 Testing Report website. If you have additional questions you may email

Provider Relief Fund Reporting Update
Reporting Deadline Extended Indefinitely

With anticipation like small children on Christmas Eve, RHCs waited for the unveiling of the Provider Relief Fund Reporting Portal on January 15, 2021. I hit my browser refresh button at 12:01 Eastern time expecting to see a beautiful portal and starting the sprint to February 15th when our RHCs (and 200,000+ other healthcare providers) must report how they used the provider relief funds received in 2020. I waited and waited and sometime around 10:00 AM Eastern time the portal appeared.

The first thing I noticed was a statement that read “After completing registration, providers will be notified when they should re-enter the portal to report on the use of PRF funds. This functionality is not currently available.” I guess I should have started with the press release that announced that the February 15, 2021 reporting deadline was pushed back indefinitely, but you could go into the portal and register, you just could not report as of now. The press release can be found here. Read More
Understanding the 2021 E & M Coding Changes
What Do RHC Providers and Coders Need to Know

Beginning January 1, 2021, new coding guidelines went into effect for office and outpatient evaluation and management services. This is the first major change to E & M coding in decades. These changes apply to RHCs & all other provider types which report professional services in an office or outpatient settings. There are both changes to the CPT® code descriptions for 99202 through 99215 as well changes in how the level of service is assigned. We will discuss the changes in coding guidelines first.

The E & M level is now determined by either the complexity of medical decision making OR the total time that the provider spends on the evaluation and management of the patient on the date of service. Either criterion can be used on an encounter-by-encounter basis by the provider if the clinical documentation supports the level of service. Other elements of clinical documentation, such as history and physical exam, should still be documented to the extent they are medically appropriate and provide clinical information to ensure continuity of care and medical necessity.   Read More
The Value of Becoming a Patient Centered Medical Home

Patient engagement is at the heart of a Patient Centered Medical Home. Becoming a recognized PCMH through accreditation demonstrates that you are taking extra steps to implement patient-centered care through improved coordination, education, access, communication and helping to reduce the high cost of medical care.

The PCMH model focuses on the whole patient with emphasis on accessible services, comprehensive team-based care, quality, and safety resulting in improved outcomes and higher patient satisfaction.   Read More
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