Assuming the prospective clinic site meets location and staffing requirements for federally certified Rural Health Clinics, the RHC certification process can take anywhere from 4 to 6 months or longer. The certification wait-time should not discourage prospective clinics from seeking RHC certification as this affords time to prepare the clinic space for survey.

1. Contact CRHC Rural Health Clinic Support Services
   The Colorado Rural Health Center provides comprehensive support services specifically designed to assist providers through the entire RHC certification process. An RHC support services brochure is also accessible by clicking the support services link. For more information contact CRHC at: 303.832.7493 or toll‐free from rural Colorado 800.851.6782 or email at info@coruralhealth.org.
   
   
2. Determine whether or not you meet the following requirements:
   1. Is the location in a non‐urbanized area?
      The federal government utilizes 18+ definitions of rural with each definition tailored to a specific federal program including Rural Health Clinics. To be eligible for RHC certification the physical address of the prospective clinic site must be located in a “non-urbanized area.” Visit the Health Resources and Services Administration web page for information and rural definitions.  Go to the Rural Assistance Center’s website and complete the “Am I Rural” fields to determine if the prospective clinic location qualifies. After entering the clinic address and clicking “next” be sure to check the “CMS - Rural Health Clinics Program” before continuing.
      
      
   2. Is the location a designated shortage area?
      The geographic area in which the clinic is located must have either a Health Professional Shortage Area (HPSA) or Medically Underserved Area (MUA) designation. To find out if your community is in a HPSA or MUA, visit the Health Resources and Services Administration (HRSA) web page. If you are not located in a HPSA or MUA, call the CDPHE Primary Care Office at 303.692.2470 for information on the criteria and application process.
      
      
   3. Does your clinic meet staffing requirements?
      The clinic must have a healthcare staff that includes one or more physicians and one or more physician’s assistants or nurse practitioners. A physician, nurse practitioner or physician’s assistant must be available to furnish patient care services at all times during the clinics regular hours of operation. A nurse practitioner or physician’s assistant must be available to furnish patient care at least 50% of the clinics regular hours of operation. The physician will provide the medical direction for the clinic’s healthcare activities and consultation for and medical supervision of healthcare staff. The physician must be present for sufficient periods of time, at least once in every 2 week period to provide medical direction, medical care services, consultation and supervision.
      
      
   4. Does the clinic provide the following six lab tests?
      The clinic must provide the following six lab tests directly on clinic premises:
      • Chemical examinations of urine by stick or tablet methods or both (including urine ketones).
      • Hemoglobin or Hematacrit
      • Blood sugar
      • Examination of stool specimens for occult blood
      • Pregnancy tests
      • Primary culturing or transmittal to a certified laboratory
        
        
   5. Additional requirements and considerations:
• Emergency Services
  The clinic must provide medical emergency procedures as a first response to common life-threatening injuries and acute illness and, at minimum, must have available the drugs and biologicals commonly used in life saving procedures such as analgesics, anesthetics (local), antibiotics, anticonvulsants, antidotes and emetics, serums and toxoids.
  
  
• Services Provided through Agreements and Arrangements
  The clinic must have agreements or arrangements with one or more providers or suppliers participating under Medicare or Medicaid to furnish other services to its patients, including inpatient hospital care, physician(s) services (whether furnished in the hospital, the office, the patient’s home, a skilled nursing facility or elsewhere) and additional specialized diagnostic and laboratory services that are not available at the clinic. If the agreements are not in writing there must be evidence that patients referred by the clinic are being accepted and treated.
  
  
• Annual Evaluation
  The clinic must carry out and arrange for an annual evaluation of its total program.
  
  
• Committees
  The clinic must establish two committees. One committee for the purpose of annual policy and procedures review and one committee for the review of the clinic’s annual evaluation.
  
  
3. Conduct a Financial Feasibility Study
   To be fiscally viable a clinic’s payer mix should generally consist of 20% Medicare, 30% Medicaid and 50% “other”. CRHC highly recommends that clinics seeking RHC certification conduct an RHC Financial Feasibility Study in order to determine what the impact of the RHC program and reimbursement will be on the financial operations of the clinic. For more information on the RHC Financial Feasibility Study contact CRHC directly at: 303.832.7493, 800.851.6782 or info@coruralhealth.org.
   
   
4. Request an initial application to become a Medicare certified RHC
   Visit the CDPHE Health Facilities Division (HFD) web page or call 303.692.2800 to inform them of your interest in becoming an RHC. They will provide you with pertinent information necessary for you to begin the certification process including the letter of intent request for a health facility/agency license application and/or certification packet. Once received by the HFD, the requestor will receive information specific to the certification process including how to access the required RHC certification and Medicare enrollment forms.
   
   
5. Review the packet of information and return necessary materials
   Complete the forms and return them to the appropriate agencies as directed by the HFD. After the facility submits their 855A application, it generally takes at least 30 days for the fiscal intermediary (Novitas Solutions, INC.) to approve it and notify CDPHE.
   
   
6. Prepare and Wait for Survey
   Once all RHC and Medicare enrollment forms have been approved, notification will be sent from Novitas Solutions, INC. to the HFD indicating that the clinic is ready for survey. The clinic should prepare for and expect significant downtime between the approval of the application and the certification survey. RHC surveys are not scheduled and the clinic will not be notified, and so the clinic is advised to operate under the assumption that the certification survey is imminent. Contact CRHC at 303.832.7493 or 800.851.6782 and schedule a Rural Health Clinic Mock Survey. A Rural Health Mock Survey is a live replication of a RHC certification survey and focuses on:
   • Onsite inspection
   • Review of policies and procedures
   • Medical records review
   • Annual evaluation
     
     
7. Undergo Survey
   The survey is generally one day and if all criteria are met, with no deficiencies identified, the recommendation for the effective date of certification to be the day of the survey, however, this is ultimately determined by CMS. If there are deficiencies, the effective date of certification is when the provider demonstrates substantial compliance with the issues cited. CDPHE will inform you as to whether you have met all the requirements for certification at an exit conference at the end of the survey. If deficiencies are identified, you will have to submit a plan of correction and a second survey will be conducted to determine if corrections have been made. HFD will make a recommendation regarding certification to the Denver Regional office of the Centers for Medicare and Medicaid Services (CMS, formerly HCFA). An official letter or notice of approval will be sent to you in approximately 30 days. This letter will indicate the effective date of certification as well as your provider number. It is extremely important that the clinic does not treat Medicare beneficiaries until the Regional office of CMS has issued this letter of approval with your provider number.
   
   
8. Get your Medicaid certification
   After obtaining the initial certification from Medicare, you need to contact the State Medicaid office (the Office of Health Care Policy and Financing) to obtain Medicaid enrollment forms in order to be able to serve Medicaid clients/patients and receive RHC reimbursement. Contact them at 303.866.2993.

Please do not hesitate to ask questions! Contact CRHC’s RHC staff at info@coruralhealth.org or call us at 800.851.6782.