The year-end COVID-19 relief package made significant changes to Medicare reimbursement for Rural Health Clinics (RHC).  While increases to the cap for freestanding RHCs are a positive development, other changes will have implications for provider-based RHCs.

Attached and below are policy recommendations of further modernizations to be made to the program in the 117^th Congress.

Section 130 of the bill made the following notable changes to the RHC Program   

• Increases the freestanding RHC limit to $100 beginning April 1, 2021 taking it to $190 in 2028.
• Subjects all “new” (certified after 12/31/19) RHCs, both freestanding and provider-based, to the new per-visit cap.
• Eliminates the exemption of payment limit for new provider-based RHCs. Any provider-based RHC certified after 12/31/19 will be subject to the same limits as freestanding facilities, meaning no new provider-based RHCs can receive uncapped cost-based reimbursement.
• Provider-based RHCs in existence as of 12/31/19 would be grandfathered-in at their current All-Inclusive Rate (AIR) and would receive their 2020 AIR plus an adjustment for MEI (the Medicare Economic Index) or their actual costs for the year.

Technical Correction Recommendation

• Addressing provider-based RHC’s who were under construction and/or in development as of date of enactment. The backdating for new provider-based RHC of the December 31, 2019 is not acceptable and should be changed to April 1, 2021, when the change goes into effect. That will give hospitals currently in the process of converting RHCs an opportunity to address their planning and complete pending conversions.  In the middle of a pandemic, as much flexibility should be given to rural providers as possible.

RHC Modernization Policy Recommendations   

• Permanently enable all RHCs to serve as distant-site providers for purposes of Medicare telehealth reimbursement and to set reimbursement for these services at their respective AIR. Additionally, these services should be counted as a qualified encounter on the Medicare cost report.
• Modernize physician, physician assistant, and nurse practitioner utilization requirements to allow for arrangements consistent with State and local law relative to practice, performance, and delivery of health services.
• Continue cost-based reimbursement without a per-visit cap in exchange for requiring provider-based RHCs reporting of quality measures, perhaps per the Uniform Data System (UDS) or another like system. Provider-based RHCs would use the higher rate to pay for their participation in a quality program.
• Create an option for low-volume facilities (perhaps those meeting frontier and/or volume threshold) to automatically be eligible to receive a provider-based designation exception to address low-volume issues.
• Allow RHC’s the flexibility to contract with physician assistants and nurse practitioners, rather than solely employment relationships.
• Remove outdated laboratory requirements.

Pennsylvania Secretary of Health Dr. Rachel Levine announced beginning Tuesday, January 12, regional drive-thru and indoor walk-in testing clinics will be held in Bradford, Clarion, Fulton, Lancaster and Pike counties. The counties with testing sites will continue to change weekly over the next seven weeks so that 61 counties will eventually be covered by dedicated pop-up testing sites over a 12-week period.

“Over the past several weeks, we have seen a rapid increase of positive case counts reaching record-high levels, which gives us significant cause for concern,” Dr. Levine said. “In fact, every county now has a positivity-rate greater than five percent, which is alarming. In addition, 21 counties have percent positivity above 20 percent.”

From March through January 7, the department has received 7,831,153 polymerase chain reaction (PCR) test results, which roughly equates to 61.1 percent of the population. From May through January 7, the department has received 805,895 antigen test results. The total number of tests combined equates to 8,637,048, roughly 67.4 percent of the total Pennsylvania population.

Pennsylvania is currently in the yellow level of testing – 2,000 to 2,999 tests per 100,000 population – according to the White House Task Force Weekly Report.

The department extended and expanded its initial contract with AMI to perform pop-up testing in counties across the state. Counties under the initial contract, as well as the total number of patients tested, can be found here. The initial AMI testing and the extension were funded by the federal ELC Enhancing Detection grant.

Director of Testing and Contact Tracing, Michael Huff, added that testing is going well at these sites.

“With the capacity to test up to 450 people per day, these sites are getting thousands of people tested during the course of the days-long site set-ups,” Huff said. “Testing is more important than ever in Pennsylvania and we will continue with a robust testing plan to keep Pennsylvanians safe and identify cases of COVID-19.”

The department believes that increased testing in the counties will assist in determining the prevalence of the virus and assist the county in moving forward. Concerning counties, identified as those with percent positives above five percent, which is currently every county in the state, can be found on the Early Warning Monitoring Dashboard. Each county is being monitored as the state continues to examine all available data.

“We are grateful for our tremendous partnership with AMI and participating county entities to provide pop-up testing in five regions across the commonwealth,” Dr. Levine said. “The AMI testing sites will be open to anyone who feels they need a test. It is important that even people with no symptoms who test positive isolate to stop the spread of COVID-19.”

Beginning Tuesday, January 12, drive-thru testing clinics will be held to contain the recent rapid increase in COVID-19 cases in the following three counties:

• Bradford;
• Clarion; and
• Pike.

Fulton and Lancaster counties will also begin Tuesday, January 12, but will be drive-thru and indoor walk-in clinics.

Testing will be available daily from 9:00 AM to 6:00 PM starting Tuesday, January 12 through Saturday, January 16.

The testing site locations and addresses are:

• Bradford County:  Towanda Airport, 415 Airport Road, Towanda, PA, 18848;
• Clarion County:  100 Clarion County Park, Shippenville, PA;
• Fulton County:  American Legion, 411 North Fifth Street, McConnellsburg, PA, 17233;
• Lancaster County:  Old Sears Auto Center, 142 Park City Center, Lancaster, PA, 17601; and
• Pike County:  Dingmans Ferry Park and Ride, 1838 Route 739, Dingmans Ferry, PA, 18328.

Up to 450 patients can be tested per day. Mid-nasal passage swab PCR tests will be performed. Testing is on a first-come, first-serve basis and is completely free to all patients. Testing is also open to individuals who are not county residents. Patients must be ages three and older and are not required to show symptoms of COVID-19 in order to be tested. No appointment is necessary. Patients are encouraged to bring a photo-ID or insurance card. Registration will also be completed on-site. The turnaround time for testing results is two to seven days after testing.

Individuals who are tested should self-quarantine while they await test results. Individuals who live with other people should self-quarantine in a private room and use a private bathroom if possible. Others living in the home with the individual awaiting test results should also stay at home. The department has additional instructions for individuals waiting for a COVID-19 test result. Individuals who test positive will receive a phone call from AMI while individuals who test negative will receive a secured-PDF emailed to them from AMI.

For the latest information for individuals, families, businesses and schools, visit “Responding to COVID-19” on pa.gov.

Pennsylvania’s COVID-19 vaccination distribution plan was designed to be fluid and flexible to meet guidance and recommendations from the federal government. Governor Tom Wolf and Secretary of Health Dr. Rachel Levine announced the fourth version of the plan, detailing the updates and how the state is working to ensure safe, swift implementation.

“Vaccinations are an important tool in stopping the spread of COVID-19, and the Pennsylvania Department of Health and the Pennsylvania Emergency Management Agency have done a lot of hard work to facilitate a smooth, strategic vaccine rollout,” Gov. Wolf said. “But most of the vaccine distribution process is controlled by the federal government and unfortunately, that means there are a lot of unknowns.

“However, my administration is doing everything we can now to prepare for the day when the vaccine is more widely available. There are hopeful signs we must embrace. They will help us regain control in a time when many things may seem very out of control.”

The first shipments of vaccine to Pennsylvania are being given to health care workers, and through the Federal Pharmacy Partnership with information the Department of Health has shared with the federal government, people working and residing in the state’s long-term care facilities have also begun to receive the vaccine. This work continues.

While the vaccine supply remains limited the department’s goals are to prioritize persons who receive the vaccine to maximize benefits and minimize harms caused by the virus. Ongoing goals remain to promote justice, mitigate health inequities, and promote transparency.

Getting Pennsylvanians immunized with a safe and effective COVID-19 vaccine is an essential step in reducing the number of cases, hospitalizations and deaths. The Department of Health guides the distribution and administration of the COVID-19 vaccine throughout 66 of the 67 counties in the commonwealth. Philadelphia County receives independent federal funding, its own vaccine allotment, and is establishing its own COVID-19 vaccination administration plan.

The state’s vaccination plan follows the blueprint set forth by the Centers for Disease Control and Prevention (CDC) regarding a COVID-19 Vaccination Plan. The plan is an interim one that is being continuously updated to reflect the latest recommendations from the Advisory Committee on Immunization Practices (ACIP) and other guidance available and feedback received.

Dr. Levine provided details of the newly revised state plan.

“This update aligns our plan with the latest recommendations from the ACIP and CDC,” Dr. Levine said. “Phase 1A has been further defined to identify specific health care providers. Phase 1B is now a significantly larger group of people that includes people age 75 and older, those with significant health issues and essential workers. This update also creates a Phase 1C, which is those people age 65-74 and people with high-risk conditions such as cancer, COPD, hearth conditions and pregnant women, and those essential workers not included in Phase 1A or B.”

When more vaccine is available, anyone who was not previously covered and is age 16 and older, will now be vaccinated in Phase 2.

The revised plan as posted on the department’s website includes a comment form for all interested parties to provide input to be considered by the department. This form helps to fulfill the administration’s goal of promoting transparency and making this fluid process as inclusive as possible.

“Our recent success in slowing the spread of the virus, and the hope that we’ve been given with the introduction of these vaccines should energize all of us to continue the fight against this disease,” Gov. Wolf said. “We need to remain patient as vaccine distribution expands and the Department of Health works to keep everyone informed of the status of vaccine.

“It will take time, but a future without COVID-19 is possible, and I thank all Pennsylvanians for joining me in fighting for that future.”

The most up-to-date information regarding the COVID-19 vaccine, including the fourth version of the plan can be found on the vaccine section of the department’s website.

The Pennsylvania Department of Health highlighted that Pennsylvania is above the average national testing rate as noted in the White House Task Force Weekly Report dated January 3.

According to the report, Pennsylvania was at the yellow level for number of tests performed per 100,000 people for the previous week. The yellow level is 2,000 to 2,999 tests per 100,000 population.

Director of Testing and Contact Tracing Michael Huff reported that to date, the department collected results from 8,466,597 COVID-19 PCR and antigen tests statewide. Over the past 30 days, the department reported an average of 55,208 PCR tests and 14,421 antigen tests daily, for a total of nearly 69,629 tests each day on average.

“We want Pennsylvanians to know that if they need a test, one is available,” Sec. of Health Dr. Rachel Levine said. “This week, we have added five free testing sites and will continue to expand testing opportunities across the state weekly. As COVID-19 remains a threat in our communities, we need to take precautions to keep ourselves safe by monitoring ourselves for COVID-19 symptoms, finding a testing site near to us if we have symptoms and staying home if we are sick.”

In partnership with AMI Expeditionary Healthcare (AMI), Pennsylvania offers COVID-19 testing over the next 12 weeks as five strike teams will provide regional testing for 61 counties. The six counties not receiving testing from AMI have county health departments providing other means of COVID-19 testing.

The county pop-up testing sites are open from 9 a.m. to 6 p.m. All tests are free and are on a first-come, first-served basis. The department provides an update each week regarding the testing locations for the following week.

The White House Report also noted that Pennsylvania has seen a decrease in new cases and a decrease in test positivity. Pennsylvania had 392 new cases per 100,000 population, compared to a national average of 413 per 100,000. According to the report, Pennsylvania’s percent positivity is at a rate at or above 10.1%, or the 21st highest rate in the country.

Learn more about testing and find a map of COVID-19 testing sites here.

You can find the weekly White House Task Force Reports available on the department’s website here.

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