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Critical Access Hospitals: Medication Safety Initiative


Health Services Advisory Group, Inc. (HSAG) has been contracted with the Florida Department of Health, Office of Rural Health, to conduct a patient safety initiative with a focus on medication safety for Critical Access Hospitals (CAHs) since 2003. In addition, as the Medicare Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Arizona, California, Florida, Ohio, and the U.S. Virgin Islands, HSAG offers technical assistance to Medicare providers on the Coordination of Care: Medication Safety initiative which focuses on reducing hospital readmissions and admissions and reducing the prevalence of Adverse Drug Events (ADEs) in Medicare beneficiaries.

About Critical Access Hospitals

A Critical Access Hospital (CAH) is a hospital that is reimbursed by Medicare on a cost basis (i.e., for the reasonable costs of providing inpatient, outpatient, and swing bed services). The reimbursement that CAHs receive is intended to improve their financial performance and thereby reduce hospital closures. CAHs are certified under a different set of Medicare Conditions of Participation that are more flexible than the acute care hospital Conditions of Participation.

The following providers may be eligible to become CAHs:

  • Currently-participating Medicare hospitals;
  • Hospitals that ceased operations on or after November 29, 1989; or
  • Health clinics or centers (as defined by the State) that previously operated as a hospital before being downsized to a health clinic or center.

According to the Centers for Medicare and Medicaid Services (CMS), a facility that meets the following criteria may be designated by CMS as a CAH:

  • Is located in a State that has established a State Medicare Rural Hospital Flexibility Program;
  • Has been designated by the State as a CAH;
  • Is located in a rural area or is treated as rural;
  • Is 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 and beds that are within distinct part units);
  • Demonstrate compliance with the CAH Conditions of Participation found at 42 CFR Part 485 subpart F; and
  • Furnish 24-hour emergency care services 7 days a week.

A CAH may also be granted "swing-bed" approval to provide post-hospital Skilled Nursing Facility-level care in its inpatient beds. In the case of hospice care, a hospice may contract with a CAH to provide the Medicare hospice hospital benefit. In addition to the 25 inpatient CAH beds, a CAH may also operate a psychiatric and/or a rehabilitation distinct part unit of up to 10 beds each. These units must comply with the Hospital Conditions of Participation.