CMS Releases Intermediate Policy on RHC Rurality Determinations

Nathan Baugh, Executive Director, and Sarah Hohman, Director of Government Affairs


CMS officially released the interim process that will be used in determining RHC rural location determinations following the Census Bureau’s definition changes.

The interim process is as follows:

  • RHC applicants or relocating RHCs will meet the rural location requirement if the physical address is “non-urbanized” or in an “urban cluster” per the 2010 Census Bureau Data, OR if the physical address is not an urban area per the 2020 Census Bureau Data
  • Both 2010 and 2020 Census Bureau data can be found here

Over the last several months, NARHC has escalated this issue in the absence of a CMS policy, including via a letter to the CMS Administrator and by engaging our rural champions in Congress on the issue. Last week, Senator Barrasso (WY) highlighted the need for a CMS policy to HHS Secretary Becerra at the 4:14 mark in a Senate Finance hearing.

We are pleased to see that this policy preserves the historical location requirements for the RHC program, as we requested. NARHC would like to thank everyone who has engaged on this issue in order to bring increased attention to its implications on the RHC program.

With any questions, please contact Nathan Baugh, NARHC Executive Director, at or Sarah Hohman, NARHC Director of Government Affairs, at