The Final Rule Issued
On November 2nd, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2024 Medicare Physician Fee Schedule (MPFS) Final Rule and the CY 2024 Medicare Outpatient Prospective Payment System (OPPS) Final Rule, finalizing several Rural Health Clinic (RHC) specific policy proposals.
Extreme gratitude to our advocates at the National Association of Rural Health Clinic (NARHC) for submitting comments in September during the rule making process timeline as to how CMS proposals may impact the RHC community. Much appreciation to NARHC for the suggested changes submitted to ensure that safety net providers are able to take full advantage of the expanded benefits. Thank you! We encourage you to join NARHC’s Washington, D.C. team for a webinar on December 11th, 2023, where they will discuss the final rule and answer questions about implementation of these various policy proposals. Register for the webinar here. If you are unable to attend rest assured, we will be in attendance.
Background
Currently, only two organizations have the authority in the RHC regulations (§491.2(1)) to certify NPs to practice as primary care NPs in RHCs, the American Nurses’ Association and the National Board of Pediatric Nurse Practitioners and Associates. However, CMS acknowledged that there are various other national certifying organizations with standards for Nurse Practitioners that more fully represent available certifications available for NPs.
CMS Proposed
They proposed to change the definition of nurse practitioner at § 491.2(1) from:
Is currently certified as a primary care nurse practitioner by the American Nurses’ Association or by the National Board of Pediatric Nurse Practitioners and Associates;
to:
“Be certified as a primary care nurse practitioner at the time of provision of services by a recognized national certifying body that has established standards for nurse practitioners and possess a master’s degree in nursing or a Doctor of Nursing Practice (DNP) doctoral degree.”
CMS listed examples of other certifying boards, including the American Academy of Nurse Practitioners Certification Board (AANPCB), American Nurses Credentialing Center (ANCC) Certification Program, Pediatric Nursing Certification Board (PNCB), and the National Certification Corporation (NCC), however these would not be explicitly listed in the regulation.
CMS also sought comments on whether NPs working in RHCs should be required to be certified in “primary care” or if that specificity should be removed from 491.2.
NARHC commented in support of these changes to expand the breadth of allowable certifying entities that will better capture the full suite of NPs adequately trained to provide care in RHCs, and to increase the flexibility of RHCs to utilize the providers best equipped to join its care team, without limitations that such a “primary care” specification may require.
CMS finalized both definition changes as proposed.
Please contact Melissa Jones, CRHCP
Rural Health Clinic Senior Associate, Burrows Consulting at melissa@burrowsconsulting.net with any questions.
Reference Sarah Hohman, 11/07/2023 <https://www.narhc.org/News/30193/CMS%2DFinalizes%2D2024%2DRegulatory%2DUpdates>
