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CAH
Conversion
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Why would a hospital consider conversion to a CAH?
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The main goal of the program is to improve the financial viability and
stability for the hospital. If the hospital is in need of improved financial
status to assure success and viability, and if conversion appears to be
a logical move based on the criteria, then the hospital should strongly
consider conversion. A proper financial feasibility study will identify
all of the benefits and issues for a hospital as well as help guide the
hospital to a proper decision. The main benefit of converting to a critical
access hospital is the opportunity for higher Medicare reimbursement.
Currently, hospitals receive inpatient reimbursement for inpatient and
outpatient hospital expenses on a cost basis, which for most small, rural
hospitals should be far higher. Other potential benefits from converting
to CAH status include:
- Possible cost reductions as a result of the operating guidelines
for a CAH;
- Expansion of services and support through the relationship with
the network hospital;
- Increased focus and presence in addressing the community's health
issues; and
- Potential access to grant dollars from the Colorado Critical Access
Hospital Technical Assistance Grants to facilitate the transition.
To what extent should the community be involved in
preparations to become a CAH? back
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Involvement of the community in a needs assessment and planning effort
is essential if the conversion to a CAH is to be supported by the community
and ultimately be successful. Networking with all community service delivery
resources is vital to successfully address the health needs of rural citizens
and to ensure the survival of the rural healthcare infrastructure. Again,
CRHC is prepared to assist rural communities and hospitals in this process.
Do the hospital board and medical staff need
to be involved in the CAH designation process? back
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Emphatically, yes! While there is no specific regulatory requirement,
several dynamics drive the need for involvement of both the board and
the medical staff. The board is required to provide oversight for the
operation of the operation of the hospital, which makes early involvement
an imperative. Medical staff is potentially affected in a material way
by the manner in which a CAH is operated. Support form the medical staff
is absolutely necessary to the success of the venture. In addition, an
annual follow-up evaluation of the way in which a CAH, its network and
service affiliates address the needs of the community is required. A committee
including a member of the medical staff, a community representative, a
network representative and a board representative should conduct the evaluation.
CRHC is the recipient of a grant to assist rural communities and hospitals
in this process.
How may I obtain information concerning the CAH
program? back to index
Contact Cari Fouts, CAH Program Director at cf@coruralhealth.org or 303-832-7492.
CAH Certification
and Licensure
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How long does certification take? back
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Once a facility is prepared and has requested to be surveyed, the Health Facilities Division will add the facility to the state’s list of pending surveys. This is an unannounced
survey and, depending on workload and staffing availability, it may be 3-6 months before the survey is conducted. Processing
of CMS's notice of certification, following full compliance with requirements
for participation, will take two to four weeks. Once the certification
is approved, the fiscal intermediary requires two to four weeks to implement
the new Medicare provider number. The entire process may take up to 6 to 9 months.
What assistance is available to my facility
or community in preparing to become a CAH facility? back
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CRHC is the recipient of a federal grant to provide such assistance. This
assistance may involve community or service area surveys, reports regarding
facility performance and market share, technical assistance in complying
with program requirements, or grants in aid for planning and implementation
of activities necessary to becoming a CAH.
How will the hospital's license be affected?
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The hospital relinquishes its general acute hospital license and is issued
a new license as a CAH by the Colorado Department of Public Health and
Environment (CDPHE), Health Facilities Division.
When the State conducts Critical Access Hospital
surveys, do they survey outpatient clinics? back
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Only those that are under the same Medicare provider number as the
hospital.
After CAH Status
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Will the federal government have more control
over the hospital after the conversion? back
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No. While the rules under which a CAH operates are different from an acute
care hospital, the new designation does not give the federal government
any greater control over the hospital. The State is the primary entity
that will oversee the operation of the CAH designation program, but they
are not granted a higher level of control either.
How often are CAH's required
to conduct disaster drills? back
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There is not a specific requirement for frequency of disaster drills for
CAH's. The regulation (Condition of Participation: Physical plan and environment.
CFR 485.623) requires that staffs are trained in handling emergencies.
Number (4) under this regulation also addresses CAH preparedness consistent
with the conditions of the area it is located, i.e. tornado training drills
for the eastern plains.
The essential concern is that all staff are trained to handle the various
types of emergencies and ultimately ensure patient safety. The providers
must assess their own needs in terms of staff turnover, potential emergency
situations in their area as well as preparedness for national threats
such as bioterrorism and plan their training and drills accordingly.
Are there requirements for
personnel taking X-rays in a CAH? Do they have to be AART certified? Is
Limited Scope "certification" adequate? back
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A new Guidance/Interpretive Policy from the state Laboratory and Radiation
Services Division states that hospitals may employ limited scope x-ray
technologists. Click
here to read the policy (PDF - 384k).
Is there a specific time frame
for completing the comprehensive, individualized care plan for swing bed
patients? back to index
A comprehensive plan must be:
- Developed within 7 days after the completion of the comprehensive
assessment;
- Must conduct a new comprehensive assessment and develop a comprehensive
care plan for each individual swing bed admission;
- Prepared by an interdisciplinary team, that includes the attending
physician, a registered nurse with responsibility for the resident,
and other appropriate staff in disciplines as determined by the resident's
needs, and to the extent practicable, the participation of the resident,
the resident's family or the resident's legal representative;
- Same thirteen items addressed in the Resident Assessment must be addressed
in the care plan;
- Periodically reviewed and revised by a team of qualified persons after
each assessment; and
- Discharge summary can be written by nurse or doctor, there just needs
to be one!
We have met the requirements of our life/safety
plan of correction. Do we need to send a follow-up report to the State?
Are they going to conduct a follow-up survey? back
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No. You are not required to forward a report to them at this point.
They are not going to schedule a specific survey to follow-up on your
corrections. However, if they are in the area for another reason (nursing
home survey, visiting another facility) they will stop in to re-survey.
If you would like to (although it is not required) notify the CDPHE Health
Facilities Division that you have implemented corrections, contact Carol Cambria in the Health Facilities Division at 303-692-2830 or email her at
carol.cambria@state.co.us.
When a patient is transferred from
a metro hospital to a CAH for Swing Bed admission, are there any regulations
regarding the type of transfer required?back
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The method of transport should be determined according to medical
necessity based on the patient's condition. Medicare will not reimburse
for ambulance transport unless it is medically necessary. If the physician
determines that ambulanced or skilled transport is required, he/she should
document this in written transfer orders. If ambulance or skilled transport
is not deemed medically necessary by the physician, the patient should
be transported via private vehicle.
Can non-Medicare patients be
admitted to Swing Beds? back
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A CAH can admit patients with Medicaid,
any other type of insurance, or any type of payment source. Any patient
may be admitted to a Swing Bed if he/she meets the medical qualifications
and the attending physician certifies the admission. For non-Medicare
patients, the hospital should find out if the patient's insurance company
covers patients admitted to Swing Beds. Some State Medicaid programs
have long term care plans that cover CAH Swing Bed admissions.
Organ Procurement back
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At a minimum, the CAH is required to have an executed agreement with an
OPO. The OPO "determines medical suitability for organ donation."
If your hospital does not have the capacity for organ procurement, that
would be determined on a case-by-case basis by the OPO. You are not REQUIRED
to have the processes and equipment in place to accomplish organ procurement,
you are only REQUIRED to have an agreement with an OPO.
Does the facility have to designate
how many beds are to be used as swing beds and is there a limit on how
many can be used as swing? back
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No, the rule is that CAH in-patient beds can be used for either SNF or
acute care, as long as the total number of in-patient beds does not exceed
25. These beds can be used as any combination of acute or swing. All licensed
beds could be all swing or all acute as necessary, the CAH just cannot
exceed the 25 bed limit.
How
do CAHs in Colorado conduct background checks on prospective hires? back
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Most Colorado CAHs utilize an outside contracted service to conduct background
checks on employees, after a contingent offer of employment is made. Contact
the Center at info@coruralhealth.org or 1-800-851-6782 to obtain a list
of background screening services and fees.
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