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Relocation/CAP
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1/6/2021 @ 2:54:00 PM
Post 1 of 5

Contributor: Karen Robinson, Baker Tilly

If a Critical Access Hospital relocates an existing hospital-based RHC (one approved by Medicare prior to December 31, 2019), will that relocated RHC then be viewed as “new” by Medicare and thus subject to the cap imposed on independent rural health clinics?
1/6/2021 @ 3:02:00 PM
Post 2 of 5

Contributor: Charles James, North American Healthcare Management Services

No. That will not be considered a new clinic. That clinic’s rate should not be affected.

Charles A. James
North AmericanHMS
via Outlook Mobile

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1/6/2021 @ 3:08:00 PM
Post 3 of 5

Contributor: Patty Harper, InQuiseek Consulting

The RHC would file a change of information under the existing CCN to report the relocation. The new location must meet all of the location requirements. The regional office of CMS, the state agency or the accreditor may request that the new location undergo a survey in some cases of relocation. However, the original CCN would stay with the RHC. It would not be a new RHC if the relocation is done correctly.

Patty Harper, RHIA, CHTS-IM, CHTS-PW, CHCR
Healthcare Consultant/Principal
318-243-2687 (Cell)
866-855-0683 (Fax)

940 Ratcliff Street
Shreveport, LA 71104

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1/6/2021 @ 3:22:00 PM
Post 4 of 5

Contributor: Karen Robinson, Baker Tilly

Thank you Mr. James, follow-up question.  Are provider-based RHC's that expand or relocate to an on-campus location OR move off-campus, required to be resurveyed?
1/6/2021 @ 3:27:00 PM
Post 5 of 5

Contributor: Nathan Baugh, National Association of Rural Health Clinics

We will likely need to wait for regulation to know for sure how this will be handled.

Nathan Baugh
Director of Government Affairs
National Association of Rural Health Clinics
1009 Duke Street
Alexandria, VA 22314
(202) 543-0348


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