NARHC Policy and Advocacy

NARHC’s policy and advocacy efforts advance the NARHC mission, enhancing the ability of RHCs to deliver cost-effective, quality health care to patients in rural, underserved communities. NARHC’s government affairs team, based in Washington, D.C. serves as the primary resource to Congress, federal agencies, and the Administration on federal Rural Health Clinic issues.

Together with the NARHC Policy Committee, we focus on both regulatory and legislative options to increase access to care, remove unnecessary regulatory burdens, protect the integrity of the RHC program, and enhance reimbursement policies that incentivize and support rural, outpatient health care services. Advocacy and comment letters sent to CMS, HHS, and Members of Congress can be found here.

Our team develops policy priorities and strategies to accomplish these priorities. Additionally, we develop materials intended to engage RHCs in federal advocacy efforts. For more details on how to make your voice heard or with any questions, please email Sarah Hohman, NARHC Director of Government Affairs, at Sarah.Hohman@narhc.org.

NARHC 2023 Policy Priorities

1. Rural Health Clinic Burden Reduction Act

Signed into law by President Jimmy Carter in 1977, the rural health clinics (RHC) program was designed to improve access to health care in rural, underserved areas. Over forty-five years later, we are pleased to report that there are over 5,200 RHCs providing quality care to rural and underserved patients. However, as healthcare evolves, several program policies are in need of modernization to reflect the changing world. The Rural Health Clinic Burden Reduction Act would accomplish this through the following provisions:

  1. Modernizes RHC physician supervision requirements by aligning them to state scope of practice laws governing PA and NP practice.
  2. Removes the requirement that RHCs must “directly provide” certain lab services on site and allows RHCs to instead offer “prompt access” to these services.
  3. Allows RHCs the flexibility to contract with or employ PAs and NPs.
  4. Maintains status quo location eligibility, allowing RHCs to be located in an area that is not in an urban area of 50,000 or more, given that the Census Bureau no longer utilizes the term “urbanized area.”
  5. Removes a regulatory barrier that limits RHCs provision of behavioral health services in areas experiencing a shortage of such services.

To continue this momentum, we need your help! Please visit our RHC Burden Reduction Page to learn more and to make your voice heard. 

2. Telehealth

Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19, both policy unique to RHCs and more broadly within the fee-for-service community.

For details on billing for telehealth and related services, please visit NARHC’s Telehealth Policy page.

NARHC continues to advocate for permanent coverage of all telehealth services and a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.

3. Good Faith Estimate

Good Faith Estimate (GFE) requirements, enacted through the No Surprises Act, requires that RHCs, and all providers, issue a GFE to all uninsured or self-pay patients upon request, and when they schedule an appointment 3+ days in advance. Please visit our Good Faith Estimate Resources for more information and details regarding compliance.

While NARHC is supportive of efforts to increase price transparency for patients, we have requested that CMS engage further with providers and other stakeholders on price transparency policies that achieve these goals without adding so much complexity and cost to the scheduling process. In response to stakeholder feedback, CMS did delay Phase II of the policy, pending future rulemaking. NARHC will remain engaged on this issue.

4. Medicare Advantage

Medicare Advantage enrollment has surpassed traditional Medicare enrollment amongst eligible beneficiaries. While RHCs receive enhanced traditional Medicare payments in comparison with their fee-for-service counterparts, there is no statutory requirement around RHC Medicare Advantage reimbursement and RHCs will be paid the contracted amount they have negotiated with each individual MA plan. Comparatively, FQHCs are eligible for “wrap payments”, through which Medicare will pay the difference if Medicare Advantage plans reimburse less than the Medicare PPS rate.