Dear RHC Community,

On November 1, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2025Medicare Physician Fee Schedule (MPFS) Final Rule. NARHC is very pleased to report that the rule finalizes several Rural Health Clinic (RHC) specific policy proposals, as well as other provisions with implications for the RHC community, including:

  • Allowing RHCs to bill for administration of Part B preventive vaccines (COVID-19, pneumococcal, influenza, and Hepatitis B) at time of service, not entirely in a lump sum settlement on cost report, beginning July 1, 2025
  • Eliminating RHC productivity standards for cost report periods ending after December 31, 2024
  • Completely revising RHC care management billing with the elimination of the G0511consolidated code
    • Establishing new “Advanced Primary Care Management Services” billing opportunities
  • Removing Hemoglobin/Hematocrit and examination of stool specimens for occult blood from the list of required RHC lab services
  • Clarifying guidance versus regulatory discrepancies in how “primarily engaged in primary care” is defined and enforced
  • Expanding same-day billing flexibilities for dental services able to be furnished in RHC setting
  • Modifying Intensive Outpatient Program (IOP) Services payment to allow for reimbursement of three and four-service days
  • Extending Medicare telehealth flexibilities until December 31, 2025

“These significant regulatory changes for RHCs were the direct result of NARHC advocacy and a CMS-willingness to listen to, and address, Rural Health Clinic concerns,” said Sarah Hohman, NARHC Director of Government Affairs. “We thank the many RHCs, and other organizations committed to the advancement of rural health who reiterated NARHC’s comments in their own submissions, all who helped us get these proposals across the finish line and into the final rule.”

The majority of these policies will go into effect January 1, 2025, unless otherwise specified below. Please read the complete article on NARHC.org for a full analysis of what was finalized, what was not finalized, and what we’ll be advocating for in the future!

Please contact Sarah Hohman, NARHC Director of Government Affairs at Sarah.Hohman@narhc.org with any questions or other feedback.