RHC Advocacy

Rural Health Clinic Advocacy
The Kentucky Primary Care Association (KPCA) and the National Association of Rural Health Clinics (NARHC) have formed a formidable partnership aimed at advancing advocacy efforts in the healthcare sector. By combining their expertise and resources, KPCA and NARHC have been able to champion the cause of improved healthcare access and quality for rural communities in Kentucky.

This collaboration has facilitated the development of comprehensive advocacy strategies, leveraging their collective influence to raise awareness about the unique challenges faced by rural health clinics and the importance of primary care in these underserved areas. 

NARHC 2023 Policy Priorities
1. Rural Health Clinic Burden Reduction Act (S.198/H.R.3730)
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 5,300 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. Bills introduced in the 118th Congress that achieve payment parity for RHCs include:
  • H.R.833
  • CONNECT for Health Act of 2023
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.
5. Value-Based/Quality Reporting for RHCs
NARHC supports the establishment of a quality reporting program designed for RHCs. It is imperative that such a program be made available to all RHCs. RHC participation in quality programs could be greatly increased and improved if a quality payment program specifically for RHCs was created. Because the RHC payment structure is essential to the RHC program but also quite different from FFS payment, the best way to bring value into the RHC model is to design a program solely for RHCs.
6. Other Rural Health Legislation
So far in the 118th Congress, several rural health related bills have been introduced with bipartisan support. NARHC is supportive of these efforts to increase access to quality health care to patients in rural America and will continue to monitor this legislation. This may not be an exhaustive list of all bills supported by NARHC. With any questions about these bills or others, please contact Sarah.Hohman@narhc.org. *The above content is created by National Association of Rural Health Centers. For more information on NARCHC