Healthcare Design - September 2023 - 40

In F o cus
2/5
per patient average length of stay of 24 hours. REHs are prohibited from
providing inpatient services, except those furnished in a distinct part
licensed as a skilled nursing facility to furnish post-hospital extended
care services. "
Operationally, the REH designation also requires a clinician, doctor of
medicine or osteopathy, physician assistant, nurse practitioner, or clinical
nurse specialist with experience in emergency care to always be on call
and immediately available on-site within a stipulated time. The REH must
also have in place a transfer agreement with at least one Medicare-certified
hospital that is designated as a Level I or Level II trauma center.
To be eligible to convert to an REH designation, CMS states a facility
must have been enrolled and certified within the Medicare program as of
Dec. 27, 2020. Facility types include critical access hospitals, hospitals
with no more than 50 beds located within a rural area, and hospitals with
no more than 50 beds that were treated as being located in a rural area.
CMS also extended eligibility to facilities that may have already closed
after Dec. 27, 2020. In this scenario, facilities must re-enroll into the
Medicare program and fulfill all necessary REH requirements to receive
the financial support of the REH designation and re-open their doors.
Additionally, the state in which the hospital resides may also have its own
stipulations and criteria for licensure.
CHALLENGES TO REH CONVERSION
From December 2020 until implementation of the REH program, various
healthcare industry stakeholders participated in an open discussion
with CMS and provided their feedback on potential barriers expected post
rollout. Of these challenges, two reoccurring topics developed, including
the potential struggle of maintaining access to emergency medical services
(EMS) necessary to adhere to the REH transport agreement and the
impact of extended visits of behavioral health patients who often push beyond
the REH-stipulated 24-hour length of stay.
Janice Walters, COO, and Anna Anna, project director, Rural Emergency
Hospital Technical Assistance Center (REH-TAC; Harrisburg, Pa.), have
been working to provide technical assistance nationwide to rural hospitals
interested in pursuing the REH designation. From their experience,
the majority of systems do not flag EMS access as a potential barrier. As for
the concern regarding extended behavioral health visits, the REH-TAC reiterated
that the REH maximum 24-hour requirement isn't designated for
each visit, but rather an annual average taken across all visits.
40
SEP TEMBER 2023
The Spartanburg Regional
Health System's new
Union Medical Center
replacement facility will
offer rural residents
access to optimal
healthcare services in
a modern setting.
ROOM TO GROW
Design considerations for facilities that meet
the REH designation include creating a more
compact, efficient footprint, with the direct adjacencies
needed between the emergency department
and observation unit, as well as the
opportunity to connect a skilled nursing facility.
Similar to the microhospital concept, but excluding
the inpatient services, special attention
will need to be directed toward creating a costeffective
design as well as achieving operational
efficiency to allow for flexibility due to limited
staff. Designers must also consider the context
of the community, providing a financially sustainable
and scalable design with room to grow.
Many of these objectives were carefully studied
when designing Spartanburg Regional Health
System's Union Medical Center, a replacement
facility in Union, S.C., that's currently under construction.
The organization's existing rural hospital
in many ways was already operating like an
REH, with higher-acuity patients transferred to
a larger campus and provision of some inpatient
services suspended. For example, the surgery department
had been vacated and converted to a rural
health clinic. However, the constraints of the
existing facility included an aging and oversized
infrastructure, which created inefficiencies and a
lack of needed adjacencies between departments.
With the new replacement facility, direct department
adjacencies are captured through
right-sizing the new facility and seamlessly
marrying outpatient services including a rural
health clinic, pediatrics and OB-GYN care, infusion,
hematology, and oncology. The design also
accommodates a future connection for a skilled
nursing facility, with infrastructure in place to
share various back-of-house services, the central
energy plant, kitchen, and dining.
SPOTLIGHT ON
HCD CONFERENCE
For more on
this topic, find
the author speaking
with a panel in session
" E14: Rural Emergency
Hospital - The Future of
Promoting Equity and
Access to Care, " at the
2023 HCD Conference
+ Expo, Nov.
4-7 in New Orleans.
For conference and
registration details,
visit hcdexpo.com.
THE RIGHT DIRECTION
For facilities facing financial difficulty, the REH
designation could offer much-needed stability
and the opportunity to expand outpatient services,
in addition to protection from closure and
loss of emergency care. While further modifications
of the provider type are imminent, decision-makers,
stakeholders, and designers will
continuously be challenged to work together to
find the best solution for protecting rural healthcare
today and in years to come. 
Hillary Earl Crosby, AIA, NCARB, is an architect
at Earl Architects (Greenville, S.C.) and can be
reached at HILLARY_EARLCROSBY@EARL
ARCHITECTS.COM .
HCDMAGAZINE.COM
EARL ARCHITECTS
http://www.hcdexpo.com http://www.ARCHITECTS.COM http://www.HCDMAGAZINE.COM
Healthcare Design - September 2023

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