Newsletters

POSTED: March 15th, 2023
POSTED IN: 2023 Quarter 1, EM Pulse - The Official Newsletter of MOCEP,

Written by: Louis Jamtgaard, MD FACEP

In response to the nationwide trend of rural hospital closures (140 hospitals since 2010), CMS has authorized a new designation, the “Rural Emergency Hospital” (REH) for existing rural hospitals (less than 50 beds) and critical access hospitals. ⁽¹⁾ The intent of the designation is to provide the rural population with continued access to emergency services and critical outpatient services, especially in areas that may not be able to financially support a traditional inpatient rural hospital. According to a 2019 report by the Missouri Hospital Association, approximately half of all rural hospitals in Missouri lost money, and the average operating margin was less than half a percent. ⁽²⁾ In addition, of the more than 19 hospital closures in Missouri since 2015, 10 were rural. Although the reasons for closure are likely multifactorial, it begs the question whether REH status could have allowed some of these rural hospitals to remain financially solvent. 

REH will benefit from increased reimbursement through two mechanisms, for outpatient services, they will receive Outpatient Prospective Payment System (OPPS) rate plus 5% for all medicare patients, and separately they will receive an additional monthly facility payment that will increase annually with hospital market basket increases.  There is no guarantee that conversion to REH status will improve a hospital’s fiscal situation, and each hospital is responsible to determine fiscal feasibility. According to a study by the North Carolina Rural Health Research Program looking at financial feasibility, it is estimated that about 68 hospitals nationwide will consider conversion to REH status. Zero hospitals from Missouri are expected to consider conversion to REH status, whereas 16 hospitals in Kansas are likely to consider conversion. ⁽³⁾ 

Unfortunately, Missouri hospitals cannot even consider REH status, as Missouri has not yet passed state legislation establishing licensing and regulatory requirements to be aligned with federal REH designation. Currently, House Bill 402 in the Missouri General Assembly will modify existing statute to be in line with CMS designation. As of March 2023, the status of the bill remains in committee. MOCEP provided testimony in support of HB 402 in January 2023. 

It is important to mention that REH’s will be required to provide 24-hour emergency services,  in addition to diagnostic radiology services, laboratory services, pharmacy, and discharge planning services. CMS requires that the average length of stay not exceed an average of 24 hours per patient.  Staffing requirements will be similar to critical access hospitals, a MD or DO with “expertise in emergency care” must be onsite or on call and available within 30 minutes. NP or PAs may fulfill this requirement in accordance with their states’ scope of

practice laws.

As the rural health landscape continues to evolve, the MOCEP Rural EM committee will keep track of the relevant changes and keep the MOCEP membership up to date. 

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Dr. Jamtgaard currently practices in St. Joseph and Albany Missouri and chairs the MOCEP Rural EM committee. 

(1) Rural Health Information Hub. Rural Emergency Hospitals Overview. (2022, October 21). Retrieved March 1, 2023, from https://www.ruralhealthinfo.org/topics/rural-emergency-hospitals#overview 

(2) Rural Health. MHA. (2023, January 19). Retrieved March 1, 2023, from https://web.mhanet.com/rural-health/ 

(3) Pink GH, Thompson KW, Howard HA, Holmes GM. How Many Hospitals Might Convert to a Rural Emergency Hospital (REH)? NC Rural Health Research Program, UNC Sheps Center. July 2021.