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Rural Health Clinic Productivity Standards Exception

Rural Health Clinics (RHC) are subject to productivity standards that are established by CMS. Productivity standards are applied as a guideline that reflects the total combined services of the RHC staff. Failure of the RHC to meet the productivity standards indicates the RHC may be operating at an excessive staffing level and generating excessive costs. If total visits are less than the productivity standards, the productivity standards are used to calculate the cost per visit which may be subject to additional caps.

The CMS Internet-Only Manual, Publication 100-02, Chapter 13 Section 80.4 allows the Medicare Administrative Contractor (MAC) the discretion to make an exception to the productivity standards based on individual circumstances for a one-year period.

Provider's can request an exception to the productivity standards to CGS Administrator, LLC. In the written request, submit documentation to support why the RHC has not been able to meet the productivity standards. The exception is CGS's discretion, and a written request does not guarantee an approval. Written requests can be sent to RHCException@cgsadmin.com.

In order for approved exceptions to be included timely on their as-filed cost report, CGS asks Providers to submit the exception request 60 days prior to the cost reporting due date. If the exception request is submitted after the start of the desk review, the results may not necessarily be incorporated into that final settlement. In such a case, the additional documentation can be submitted as part of a request for consideration of a reopening. Ultimately, the decision as to whether or not to reopen will be left up to the MAC.

COVID-19 Public Health Emergency Rural Health Clinic Productivity Standards Exception

CMS wants to minimize the burden on RHCs who have experienced disruptions in staffing and services and have had difficulty in meeting productivity standards as a result of COVID-19 public health emergency (PHE). On May 11, 2023, the COVID-19 PHE has ended and as a result, the RHC productivity standards PHE exception is only available for cost reports beginning before May 11, 2023. If you would like to request an exception to the productivity standards relating to COVID-19 PHE, please send your request to RHCException@cgsadmin.com. Please include your provider name, provider number, cost reporting period and an explanation for your request.

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