The Medicare Conditions of Participation at 42 CFR 485.601 set forth the criteria which a hospital must satisfy to qualify as a Critical Access Hospital (CAH). Among other things, these criteria include the requirement that the CAH be located in a rural area. If a hospital is located in an urban area, CMS allows the hospital to reclassify to rural if it meets certain requirements (42 CFR 412.103).
Hall Render Killian Health & Lyman has prepared a 2016 memorandum that clarifies the Urban to Rural Re-classification process. The memo includes a list of the 15 counties in Wisconsin that are considered urban. If a CAH is located in one of the urban counties, it may have already received an urban to rural reclassification. Those CAHs should attempt to locate documentation related to their 42 CFR 413.103 reclassification, including the application and approval from CMS. This will help prove its rural status in the event of a recertification survey by CMS.
The Wisconsin Office of Rural Health (WI-ORH) maintains files on each Wisconsin CAH, which contain each CAH’s original CAH application materials and Necessary Provider documentation. The Office also has re-classification documentation for some Wisconsin CAHs. This documentation has been e-mailed to every CAH in Wisconsin, specifically the CEO, CFO and Quality Director. If you did not receive this important documentation, or have any additional questions, please contact Kathryn Miller, Rural Hospitals & Clinics Program Manager at WI-ORH.