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CMS Announces Policy to Address RHC Rural Location Determination Issues

CMS has issued a new policy and process to help determine whether a location meets the RHC rural location requirement. Read on for details.
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In March 2022, the U.S. Census Bureau finalized definition changes that left current and potential Rural Health Clinic (RHC) program participants in a state of uncertainty and confusion. The new definition no longer distinguished areas with populations of 50,000 or more as “urbanized areas.” Unfortunately, the RHC statute in Section 1861(aa) of the Social Security Act stated that clinics would only qualify for RHC status if they were “located in an area that is not an urbanized area (as defined by the Bureau of the Census).” This change in definition resulted in multiple new RHC sites being rejected based on the location requirement.

On March 31, 2023, CMS issued a new intermediate policy and process that will be used in determining whether a location meets the RHC rural location requirement. Until further notice, new RHC applicants or relocating RHCs will meet the rural location requirement if the physical clinic address is:

  • Located in a “non-urbanized” area or in an “urban cluster” per the 2010 Census Bureau data, OR
  • Not in an urban area per the 2020 Census Bureau data

CMS is expected to pass legislation to permanently address the “urbanized area” language in the RHC statue in the Social Security Act. RHCs that are planning to either establish a new clinic or relocate an existing RHC should review the 2010 and 2020 census data to verify if the clinic address will meet the rural location requirement. Those with active RHC applications for either new or relocating RHCs also should review the 2010 and 2020 census data and application status to make sure those applications are not erroneously denied.

If you have any questions about the new RHC location requirements or would like assistance, please reach out to a professional at Forvis Mazars or use the Contact Us form below.

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