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Volume X, Number 339


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CMS Announces New Payment Model for Rural Providers

On August 11, the Center for Medicare & Medicaid Services ("CMS") announced the creation of its new Community Health Access and Rural Transformation (“CHART”) Model.  The CHART Model seeks to provide new seed funding and other payment structures as well as technical support and regulatory flexibility to rural providers. The Model’s goal is to help rural communities develop a more comprehensive health care system that provides higher quality care at an affordable price. The CHART Model has two tracks for participation - the Community Transformation Track and the Accountable Care Organization Transformation Track.  

With the Community Transformation Track, CMS plans to invest up to $75 million dollars in seed money to fifteen entities that represent rural communities, which may include, state Medicaid agencies, local public health departments, Academic Medical Centers, and state offices of rural health. The entities will receive an upfront payment from CMS, and then be responsible for working with community partners such as hospitals and other state agencies to redesign the health care delivery system in their area.  

The goal of the Community Transformation Track is to offer rural providers a more stable revenue stream through predictable capitated payments, as well as more regulatory and operational flexibility. For example, waiving certain Medicare hospital Conditions of Participation to allow rural outpatient departments and emergency rooms to be paid as if they were classified as hospitals and enhancing telehealth by allowing a beneficiary’s residence to be an originating site. In September, CMS will select up to fifteen rural communities to participate in the Community Transformation Track, with the name of the participants announced in early 2021. The Community Transformation Track model is set to start in summer 2021.  

The other track is the Accountable Care Organization (ACO) Transformation Track. Providers participating in the ACO Transformation Track will enter into a two-sided risk sharing arrangement as part of the Medicare Shared Savings Program. Participants will receive advanced shared savings payments, which will vary based on the level of risk that the ACO accepts and the number of rural beneficiaries assigned to it. CMS intends to release a Request for Applications for participation in the ACO Transformation Track in Spring 2021. Up to twenty rural ACOs will be selected to participate in the model program beginning in January 2022.   

© Steptoe & Johnson PLLC. All Rights Reserved.National Law Review, Volume X, Number 237



About this Author

Kristen Wilson, Steptoe Johnson Law Firm, Professional Liability Litigation Attorney

Clients know that Kristen Andrews Wilson will help them understand and navigate the complex and complicated healthcare landscape.  Kristen’s clients include hospitals, nursing homes, and long-term care facilities, as well as independent healthcare providers.  Kristen’s practice is a unique combination of litigation avoidance via counseling and defense via litigation, when necessary.  In addition to her medical malpractice litigation practice, Kristen has experience with federal and state healthcare regulatory compliance, as well as business transactions involving...

Aleah M. Schutze Health Care Attorney Steptoe & Johnson Louisville, KY
Of Counsel

Aleah Schutze knew from a  young age that she wanted to pursue a career in healthcare and obtained a Master’s Degree in Public Health. Her decision to attend law school was born out of an altruistic desire to help more people by helping healthcare entities fulfill their individual missions.  Continuing to build her healthcare acumen, Aleah spent three years as the Associate General Counsel and Deputy General Counsel for Res-Care, Inc. (now BrightSpring Health Services), the largest diversified health and human services provider in the U.S. In that role, she gained experience in providing...