AHA Comments on the CMS’ Proposed Conditions of Participation for Rural Emergency Hospitals and CAHs

August 26, 2022

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244

RE: Comments on Conditions of Participation for Rural Emergency Hospitals and Critical Access Hospital Conditions of Participation Updates (CMS-3419-P)

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including our rural and critical access hospitals (CAHs), our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to provide comments on the Centers for Medicare & Medicaid Services’ (CMS) proposed conditions of participation (CoPs) for rural emergency hospitals (REHs) and CAHs.

Ensuring all communities have access to high quality health care is a top priority for the AHA and its members. While this commitment is true for all communities, it is clear that particular focus must be paid to rural communities. Rural hospitals and CAHs struggle to attract and retain sufficient numbers of physicians, nurses and other health care providers; they frequently are the only available source of urgent and emergent care for many miles; they have to stretch available resources due to financial constraints, especially for the past several years; and they face new challenges as a result unprecedented workforce burnout. These difficulties, compounded by the COVID-19 pandemic, played key roles in a record number of rural hospital closures in 2020 with 19 rural hospitals closing in that year alone.

We remain dedicated to making sure every community has access to critical health care services. As we continue to look for ways to meet the health care needs of rural communities, we appreciate CMS’ efforts to assist rural providers as they navigate these exceptionally difficult times. We support the agency’s proposal to allow rural providers to continue to serve their communities by becoming an REH. This new model will help preserve necessary health care services in already underserved areas. We also are supportive of CMS’ proposal to update certain CoPs for CAHs including embracing a system-level compliance approach for certain requirements, establishing a patient’s bill of rights and streamlining the CAH distance determination process.

Through this proposed rule, CMS is taking important steps to assist America’s rural hospitals and health systems. We look forward to continuing to work with the agency to ensure a seamless and thoughtful implementation of these changes.

View AHA's detailed comments below.