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Greenwood Leflore Hospital Board approves submission of Critical Access application to CMS

Tuesday, January 31, 2023, 6:35 pm News Flash Archive

Today, the Board of Trustees of Greenwood Leflore Hospital held a "Special Called Meeting," which was carried out entirely in executive session, with the public and the press excluded.

Interim CEO Gary Marchand told The Taxpayers Channel after the meeting that:

. . . the Board authorized administration to file an application for Critical Access Hospital status with CMS and to address any concerns raised [by] that agency.

"CMS" stands for "Centers for Medicare & Medicaid Services," the federal agency that administers Medicare and regulates the state Medicaid programs.

A "Critical Access Hospital" ("CAH") is a special designation of a hospital that qualifies it to receive a more generous Medicare payment schedule than that under which regular hospitals operate.

As first reported by the Greenwood Commonwealth last week, GLH would like to be designated as a CAH, because it believes that such a designation would result in GLH receiving "at least" $11 million more in revenue per year from Medicare.

However, as reported by The Taxpayers Channel in late December, Dr. Dan Edney, Mississippi State Health Officer, cautioned that even the CAH facilities are struggling to survive. In a wide-ranging public presentation made to the GLH board:

Edney stated that even critical access hospitals aren't making it economically any more, and are looking to downgrade to rural emergency hospitals, which will have only emergency and outpatient services.

To see our report on Dr. Edney's presentation, click here: GLH loses $2.16 million in November; State Health Officer Dr. Dan Edney discusses financial woes

It remains to be seen whether CAH designation can save GLH from its existential financial crisis.

But first, GLH must file its application with CMS and obtain approval, a process that begins now.

According to CMS's website, in order to qualify for CAH status, a hospital must, among other things,

Be located in a rural area or an area that is treated as rural;

Be located either more than 35-miles from the nearest hospital or CAH or more than 15 miles in areas with mountainous terrain or only secondary roads; OR prior to January 1, 2006, were certified as a CAH based on State designation as a "necessary provider" of health care services to residents in the area.

Maintain no more than 25 inpatient beds that can be used for either inpatient or swing-bed services;

Maintain an annual average length of stay of 96 hours or less per patient for acute inpatient care (excluding swing-bed services . . .);

Furnish 24-hour emergency care services 7 days a week;

Dr. Edney expressed his doubts that GLH would be able to qualify under the "35 mile" rule listed above, as there are several hospitals closer to GLH than 35 miles.

According to a long and tedious manual on the CMS website titled "Chapter 2 - The Certification Process," a hospital applying for CAH status must demonstrate its isolation from other hospitals as follows:

In demonstrating that it meets the standard for more than a 35-mile drive, a CAH applicant must document that there is no driving route from the applicant to any other CAH or hospital that is 35 miles or less in length.

The critical measure is the length of the driving route, not the "crows fly" distance between hospitals. According to Google Map's distance calculator, these four hospitals are at issue:

28 miles - South Sunflower County Hospital (Indianola)
28 miles - Tyler Holmes Memorial Hospital (Winona)
32 miles - North Sunflower Medical Center (Ruleville)
36 miles - UMC Grenada

Apparently, UMC Grenada is just outside the minimum distance of 35 miles, and should not create a problem for GLH's CAH application.

But the other three hospitals do pose a significant problem for GLH's application.

Many locals have raised the question, how could North Sunflower Medical Center in Ruleville obtain CAH status when it is so close to GLH and Bolivar County Medical Center?

The answer is hidden in the grandfather exception. CMS explains it this way:

Prior to January 1, 2006, States were able to waive the distance requirement (the requirement that the facility be 35 miles from other hospitals or CAHs) by designating a facility as a necessary provider CAH. Section 405(h)(2)(B) of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 changed the statute. As of January 1, 2006, States are no longer permitted to designate a facility as a necessary provider CAH, but existing necessary provider CAHs were grandfathered.

North Sunflower was designated a CAH by CMS in 2004, during a period when the 35 mile rule could be waived by a state certification that the hospital was a "necessary provider."

To review our reporting on GLH and its financial woes, please see here: Index of Greenwood Leflore Hospital news articles

John Pittman Hey
The Taxpayers Channel

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