A VOICE FOR ESSENTIAL RURAL HOSPITALS November 21, 2017

The Honorable Paul Ryan The Honorable Office of the Speaker Office of the Democratic Leader H-232 H-204 United States Capitol Washington, D.C. 20515 Washington, D.C. 20515

The Honorable Mitch McConnell The Honorable Chuck Schumer Office of the Majority Leader Office of the Democratic Leader S-230 United States Capitol S-221 United States Capitol Washington, D.C. 20515 Washington, D.C. 20515

Dear Speaker Ryan, Leader Pelosi, Leader McConnell, and Leader Schumer,

We write to you today urging you to not move forward with the proposed policy in the House Ways and Means Committee draft extenders package that would create an offset to modify payments for critical access hospital (CAH) swing-beds. This change in reimbursement would be devastating for CAHs, creating further financial hardships for already struggling rural hospitals and remove a critical service to rural populations.

The CAH Coalition is a consortium of innovative health care leaders representing CAH facilities across the country. The Coalition concentrates its work on the unique needs of these small, rural hospitals and ensures resources are available for rural health care for generations to come. We work with our members to develop proactive solutions, determine best practices, and advocate on behalf of CAHs and rural communities. Our sole purpose is to highlight the unique needs of CAHs so that high quality health care is sustained in rural communities.

In addition to the acute care services CAHs provide, a CAH can also designate swing-beds that Medicare beneficiaries in inpatient status can use to transition from inpatient services to receiving skilled nursing facility (SNF) services without physically changing beds within the hospital. Swing beds offer an alternative to a long- term care facility, and are particularly useful in rural areas where access to stand-alone long-term care facilities is difficult, as they can be large distances from their homes. Additionally, rural populations on average are older and sicker, making swing-beds useful in treating aging patients.

In March 2015 the Department of Health and Human Services, Office of Inspector General (HHS OIG) published a report recommending that the Centers for Medicare & Services (CMS) seek legislation to reduce swing-bed reimbursement rates for CAHs from plus 1% of allowable costs, to the daily rate paid under the SNF prospective payment system. At the time, CMS disagreed with this recommendation saying that the OIG finding, “overestimates savings by failing to incorporate important factors such as the level of care needed by swing-bed patients, transportation fees to alternative facilities, and the use of point-to-point mileage distances instead of road miles.” CMS also expressed concerns with the OIGs use of

202.266.2660 • 1120 G Street NW, Suite 1000, Washington, DC 20005 methodology on the availability of skilled nursing services at nearby alternative facilities and calculation of cost savings. These errors proved a lack of understanding on the OIG’s part of how health care is delivered in rural areas. We could not agree more with CMS’ assessment.

With 82 rural hospitals closed since 2010, CAHs play an ever increasing necessary role in the delivery of care to rural communities. The OIGs recommendations that are reflected in the Medicare extenders package shows a focus on Medicare savings, instead of ensuring rural Americans have access to quality and timely health care. There are just over 1,300 CAHs in the United States providing vital services to their communities, access to care is necessary for saving lives.

This proposed modification to payments for CAHs on swing-beds will not provide savings; instead it will shut down more hospitals and hurt patients. The original proposal for this change was made with a serious neglect of understanding of health care in rural America. We respectfully ask that this provision not be considered in the Medicare extenders package and ensure that CAHs are able to continue providing good quality care to rural patients nationwide.

If you have any questions, please contact the Executive Director of the CAH Coalition, Audrey Smith, at 202-266-2660 or through email at [email protected].

Sincerely,

Adena Greenfield Medical Center Alice Peck Day Memorial Hospital Greenfield, OH Lebanon, NH

Androscoggin Valley Hospital Angel Medical Center Berlin, NH Franklin, NC

Appleton Area Health Services Banner Lassen Medical Center Appleton MN Susanville, CA

Banner Page Hospital Banner Washakie Medical Center Page, AZ Worland, WY

Baptist Medical Center Leake Baptist Memorial Hospital – Calhoun Carthage, MS Calhoun City, MS

Bienville Medical Center Bingham Memorial Hospital Arcadia, LA Blackfoot, ID

Blue Ridge Regional Hospital Breckinridge Health, Inc. Spruce Pine, NC Hardinsburg, KY

Bucktail Medical Center Callaway District Hospital Renovo, PA Callaway, NE Cannon Memorial Hospital CentraCare Health - Long Prairie Linville, NC Long Prairie, MN

CentraCare Health – Melrose CentraCare Health – Monticello Melrose, MN Monticello, MN

CentraCare Health – Paynesville CentraCare Health - Sauk Centre Paynesville, MN Sauk Centre, MN

Central Montana Medical Center Central Valley Medical Center Lewistown, MT Nephi, UT

Chicot Memorial Medical Center Choctaw Regional Medical Center Lake Village, AR Ackerman, MS

Claiborne County Hospital Clara Barton Hospital Port Gibson, MS Hoisington, KS

Clark Fork Valley Hospital Cogdell Memorial Hospital Plains, MT Snyder, TX

Copiah County Medical Center Covington County Hospital Hazlehurst, MS Collins, MS

Cumberland Healthcare Community Memorial Hospital Cumberland, WI Burke, SD

Crosbyton Clinic Hospital De Queen Medical Center Crosbyton, TX De Queen, AR

DeWitt Hospital and Nursing Home Dr Dan C Trigg Memorial Hospital DeWitt, AR Tucumcari, NM

Eastern Plumas Health Care Edgefield County Hospital Portola, CA Edgefield, SC

Edwards County Medical Center Electra Memorial Hospital Kinsley, KS Electra, TX

Ellenville Regional Hospital Ellsworth County Medical Center Ellenville, NY Ellsworth, KS

Essentia Health St. Mary’s Hospital of Superior Eureka Community Health Services Superior, WI Eureka, SD Fall River Health Services Ferrell Hospital Hot Springs, SD Eldorado, IL

Field Memorial Community Hospital Franklin County Memorial Hospital Centreville, MS Meadville, MS

Franklin Regional Hospital Fredonia Regional Hospital Franklin, NH Fredonia, KS

Greater Regional Medical Center Gritman Medical Center Creston, IA Moscow, ID

Hardeman County Memorial Hospital Harlan County Health System Quanah, TX Alma, NE

Highlands-Cashiers Hospital Hills & Dales General Hospital Highlands, NC Cass City, MI

Hillsboro Area Hospital Hocking Valley Community Hospital Hillsboro, IL Logan, OH

Howard Memorial Hospital Jefferson Davis Community Hospital Nashville, AR Prentiss, MS

John C. Stennis Memorial Hospital Kalkaska Memorial Health Center DeKalb, MS Kalkaska, MI

Kern Valley District Hospital Lafayette Regional Health Center Lake Isabella, CA Lexington, MO

Lavaca Medical Center Lawrence County Hospital Hallettsville, TX Monticello, MS

Lincoln County Hospital Lincoln County Medical Center Lincoln, KS Ruidoso, NM

Little Falls Hospital Littleton Regional Healthcare Little Falls, NY Littleton, NH

Mariners Hospital Medina Regional Hospital Tavernier, FL Hondo, TX

Memorial Community Health, Inc. Miller County Hospital Aurora, NE Colquitt, GA Mitchell County Hospital District Morrill County Community Hospital City, TX Bridgeport, NE

Mother Frances Hospital – Jacksonville Munising Memorial Hospital Jacksonville, TX Munising, MI

North Mississippi Medical Center – Pontotoc North Sunflower Medical Center Pontotoc, MS Ruleville, MS

Optim Medical Center – Screven Orleans Community Health Sylvania, Georgia Medina, NY

Osceola Medical Center OSF Holy Family Medical Center Osceola, WI Monmouth, IL

OSF Saint Francis Hospital & Medical Group OSF Saint Luke Medical Center Escanaba, MI Kewanee, IL

Otto Kaiser Memorial Hospital Pearl River County Hospital Kenedy, TX Poplarville, MS

Perry County General Hospital ProMedica Defiance Regional Hospital Richton, MS Defiance, OH

ProMedica Fostoria Community Hospital ProMedica Herrick Hospital Fostoria, OH Tecumseh, MI

Pullman Regional Hospital Rangely District Hospital Pullman, WA Rangely, CO

Ray County Memorial Hospital River Falls Area Hospital Richmond, MO River Falls, WI

Roane General Hospital Samuel Simmonds Memorial Hospital Spencer, WV Utqiagvik (formally Barrow), AK

Sarah D. Culbertson Memorial Hospital Scott Memorial Hospital Rushville, IL Scottsburg, IN

Scott Regional Hospital Selby General Hospital Morton, MS Marietta, OH

Shenandoah Memorial Hospital Skyline Hospital Woodstock, VA White Salmon, WA Socorro General Hospital St. Andrews Campus of LincolnHealth Socorro, NM Boothbay Harbor, ME

St. Croix Regional Medical Center St Elizabeth Medical Center St. Croix Falls, WI Wabasha, MN

Stanton County Hospital Tallahatchie General Hospital Johnson, KS Charleston, MS

Taylorville Memorial Hospital The Richland Hospital, Inc. Taylorville, IL Richland Center, WI

Three Rivers Hospital Thomas H. Boyd Memorial Hospital Brewster, WA Carrollton, IL

Tippah County Hospital Transylvania Regional Hospital Ripley, MS Brevard, NC

Tri State Memorial Hospital Tyler Holmes Memorial Hospital Clarkston, WA Winona, MS

Union General Hospital Upper Connecticut Valley Hospital Farmerville, LA Colebrook, NH

Valley Health – Page Memorial Hospital Walthall County General Hospital Luray, VA Tylertown, MS

Weeks Medical Center White Mountain Regional Medical Center Lancaster, NH Springerville, AZ

Wickenburg Community Hospital Windom Area Hospital Wickenburg, AZ Windom, MN

Yoakum Community Hospital Yoakum, TX

CC: Congressman Greg Walden, Chairman, House Committee on Energy and Commerce Congressman Frank Pallone, Ranking Member, House Committee on Energy and Commerce Congressman , Chairman, House Committee on Ways and Means Congressman , Ranking Member, House Committee on Ways and Means Senator Orrin Hatch, Chairman, Senate Committee on Finance Senator , Ranking Member, Senate Committee on Finance Senator Lamar Alexander, Chairman, Senate Committee on Health, Education, Labor and Pensions Senator , Ranking Member, Senate Committee on Health, Education, Labor and Pensions