By: Emily J. Cook & Eric P. Zimmerman
Source: McDermott Will & Emery
The federal Office of Rural Health Policy (ORHP) recently released its updated list of counties and census tracts that are designated as “rural” based on 2010 U.S. Census data and the Rural Urban Commuting Area Code (RUCA) methodology.
Certain federal grant programs and Medicare payment classifications base eligibility on rural location. For many of these programs, the standard determination of rural location is whether or not a facility is located in an area outside of a metropolitan statistical area (MSA). The population shifts reflected in the 2010 Census data resulted in changes in areas designated as MSAs, which could have a significant impact on eligibility for federal grant programs and Medicare payments for facilities that were previously located outside of an MSA and are now located within an MSA. (See “New Metropolitan Areas Could Affect Medicare Payment, Regulations” for further discussion of the implications of MSA changes.) Although the Centers for Medicare & Medicaid Services has not yet adopted the 2010 Census MSAs for purposes of most geographically based Medicare payment provisions, it is expected they will do so in the coming year.
While location outside of an MSA is the standard determination of rural location, many programs that use the MSA for eligibility purposes also permit facilities that are located within MSAs, but in census tracts designated as rural RUCAs by ORHP, to be considered rural and, therefore, to become eligible or to retain eligibility for certain grants and Medicare payment classifications. Examples of programs that use the ORHP-designated rural census tracts for eligibility include the Medicare geographic wage index urban-to-rural reclassification, Critical Access designation and Medicare telehealth originating site payments. Health care facilities that were included within an MSA under the 2010 Census data should review the ORHP list of rural census tracts to determine if they may be eligible or may retain eligibility for federal grants and Medicare payment classifications that rely on the ORHP rural census tract designations.
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