The AHA today urged the Centers for Medicare & Medicaid Services to allow a wider variety of documentation to support a critical access hospital’s necessary provider designation, consistent with its past policies. “We are concerned that CMS’s recently articulated requirements around the documentation necessary to support a critical access hospital’s necessary provider designation are inappropriate and unnecessarily limited,” wrote AHA Executive Vice President Tom Nickels. “They may very well have the dire consequence of causing many CAHs to lose the designation that they rightfully obtained prior to 2006. We urge CMS to immediately remedy this issue by revising its requirements to allow alternative methods of documentation.” Interpretive guidance issued by the agency in August lists only one source of evidence that will be considered sufficient – an NP designation letter issued by the state prior to Jan. 1, 2006. “We are extremely concerned that the agency now appears to be creating a retroactive requirement that the states had actually issued such letters, which is not the case in many instances,” AHA said.

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