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Rural Hospital Flexibility Program Tracking Project

Chapter 3B
Scopes of Services in Critical Access Hospitals

David Hartley, M.H.A., Ph.D., Andrew Coburn, Ph.D., and John Gale, M.S.
University of
Southern Maine


The generic term that describes critical access hospitals (CAHs) and their precursors, including Montana's Medical Assistance Facilities (MAFs) and Rural Primary Care Hospitals (RPCHs) is "limited service hospital.1" Hospitals that adopted either of these previous delivery models often underwent a significant limitation in their scope of services. In the case of the RPCH, hospitals were barred from providing any type of surgery that was not included on the Medicare listing of approved ambulatory procedures. In some states, licensing laws also forced hospitals to eliminate birthing services, because they would lack the capacity for emergency C-sections. 

Although the operating guidelines for each of these precursor models differ from those for CAHs, some small hospital administrators and their boards have delayed or forgone conversion because of fears about restricting their scope of services, becoming "less than a hospital," or, as some have said, a "band-aid station."

This concern over the possible need to "downsize," to reduce services as well as reduce the number of licensed beds, led us to investigate some general questions about the scope of services in CAHs. Aside from limitations on length of inpatient stays and total number of beds, there is nothing in the federal conditions of participation that requires or even implies downsizing. In the first year of the Tracking Project, we suggested a more positive term to describe the process of seeking the most efficient, community-needs-oriented array of services: "right-sizing" (Tracking Project, Findings from the Field # 4). In this Year 02 report, we use new data from our survey of 217 CAH administrators to investigate several questions about scope of services:

(1) Is there a "typical" scope of services for CAHs? If so, what services are usually included, and what services are usually excluded?

(2) Are there certain services that are commonly dropped in the process of conversion?

(3) Are there some services that are typically added or expanded in the process of conversion?

(4) Has network affiliation been a factor contributing to changes in scope of services?

(5) Do hospitals that converted early in the program differ in scope of services from those that converted more recently?

In addition, based on site visits to 16 CAHs in Year 02, we present information on how CAH administrators and their boards are thinking about the relationships between specific services and their market position relative to other hospitals and to their communities. For example, are decisions about expanding some services made in response to a threat to market share, to improve the community's perception of the hospital, or for other reasons? Since this program is relatively new, we do not yet have claims data on which to base a quantitative analysis of market share and services provided. Such a project will be conducted as part of the scope of work in Year 03 of the Tracking Project. 

In thinking about which types of services to ask about as we constructed the survey, we made a decision to focus our survey questions on services that are labor-intensive as opposed to those that are capital-intensive. By capital-intensive, we mean services that require the purchase and maintenance of specialized equipment that might require a high volume of services to cover a fixed cost, e.g., CT or MRI imaging equipment.

There are three reasons for our focus on labor-intensive services. First, we assumed that small hospitals, most of which have had negative operating margins in recent years, would not be in a position to purchase and maintain the kinds of equipment needed for services that require expensive equipment. Second, many capital-intensive services require the services of medical specialties that are not commonly available at small rural hospitals, or are only available by means of specialty clinics offered once a week or less. Third, we judged that the flexible staffing allowed by the CAH license would favor services that could be staffed more intensively when the demand is up, but could shift staff to other departments when demand is down. Such services include home health, inpatient and outpatient rehabilitation services, skilled nursing, swing beds, hospice and assisted living.

In addition to the survey of 217 CAH administrators, all site visit teams made observations regarding the current scope of services, new services planned and/or services that might be discontinued. In addition, some site visit teams were able to pursue evidence of cross-training of staff such as might be expected if staff were routinely being shifted from one service to another.

Is there a Typical Scope of Services?

The Flex Program requires all CAHs to make available 24 hour emergency services and 24 hour nursing services, although they are not required to staff inpatient beds unless an inpatient is present. The Year 02 survey of CAH administrators included a set of questions covering scope of services before and after conversion to a CAH: 

(1) Did you offer this service prior to CAH conversion?

(2) Has the service remained the same after conversion?

(3) Have you dropped this service after CAH conversion?

(4) Have you limited this service after CAH conversion?

(5) Have you expanded this service since or in conjunction with CAH conversion?

(6) Have you added this as a completely new service after CAH conversion?

Services included in our analysis were:

Inpatient Surgery

Obstetrics

Inpatient Rehabilitation

Intensive Care Unit

Outpatient Surgery

Outpatient Psychiatry

Outpatient Rehabilitation

Outpatient Specialty Clinics

Rural Health Clinic

Radiology

Laboratory

Ambulance

Skilled Nursing Facility

Swing Beds

Home Health

Hospice

Assisted Living

 

While each CAH offers a unique set of services, one might begin to characterize a typical CAH by considering which services are offered by at least 75 percent of those surveyed. The following services are common to three-fourths of CAHs (See Table 1):

  • Outpatient rehabilitation.

  • Outpatient specialty clinics.

  • Radiology.

  • Laboratory.

  • Swing beds.

Additional services offered by at least half of those surveyed include:

  • Inpatient surgery.

  • Inpatient rehabilitation.

  • Outpatient surgery.

While the inclusion of swing beds and inpatient and outpatient rehabilitation services on these lists supports our hypothesis that CAHs would offer labor-intensive services with flexible staffing, radiology does not confirm it, and surgery may or may not confirm this hypothesis, depending on the type of surgery, and its accompanying specialized surgical equipment.

Table 1. Scope of Services of Critical Access Hospitals
(n=217, % in parentheses)

SERVICE

HAD SVC. PRE-CAH

EXPANDED EXISTING SVC W/ CAH CONVERSN

ADDED SVC SINCE CAH CONVERSN

HAVE SERVICE NOW

DROPPED SINCE CAH CONVERSN

INPT SURGERY

128 (59)

15 (7)

3 (1.4)

119 (56)

12 (5.5)

OB

72 (33)

4 (2)

3 (1.4)

58 (27 )

17 (7.8)

INPT REHAB

125 (58)

19 (9)

9 (4.1)

133 (61)

1 ( 0.5)

ICU

77 (35)

2 (1)

0 (0.0)

70 (32)

7 (3.2)

OUTPT SURGERY

155 (71)

48 (22)

4 (1.8)

153 (71)

6 (2.8)

OUTPT PSYCH

20 (9)

0 (0)

4 (1.8)

21 (10)

3 (1.4)

OUTPT REHAB

185 (85)

38 (18)

3 (1.4)

188 (87)

0 (0.0)

OUTPT SPEC CLINICS

179 (82)

59 (27)

5 (2.3)

183 (84)

1 (0.5)

RHC

97 (45)

16 (7)

11 (5.1)

100 (46)

8 (3.7)

RADIOLOGY

216 (100)

53 (24)

0 (0.0)

216 (100)

0 (0.0)

LAB

215 (99)

42 (19)

1 (0.5)

216 (100)

0 (0.0)

AMBULANCE

46 (21)

6 (3)

2 (0.9)

46 (21)

2 (0.9)

SKILLED NURSING

105 (48)

6 (6)

6 (2.8)

107 (49)

4 (1.8)

SWING BEDS

192 (88)

26 (12)

11 (5.1)

202 (93)

1 (0.5)

HOME HEALTH

100 (46)

13 (6)

1 (0.5)

77 (35)

24 (11.1)

HOSPICE

50 (23)

4 (2)

6 (2.8)

53 (24)

3 (1.4)

ASST LIV

25 (12)

3 (1)

7 (3.2)

28 (13)

3 (1.4)

Note: The category "limited since CAH conversion" is not shown due to the very small number of responses in this category. The column "have service now" was not specifically asked on the survey. It summarizes the net effect of the other columns. The number of hospitals as a percentage of 217 is shown in parentheses.

What Services Were Dropped? What Services Were Added?

If it was expected that CAH conversion would lead to a reduction in levels of service, Table 1 suggests otherwise. Table 1 indicates that, by and large, CAH conversion has been associated with an expansion of services rather than a reduction of level of services. Figure 1 at the end of this chapter illustrates which services expanded.

Specialty Clinics

The most commonly expanded service was specialty clinics. This may be one of the success stories of the Flex Program. As our site visits confirmed (see below), one of the benefits of network relationships has been an increase in the number of medical specialties available in CAH communities. These networks were encouraged by state office of rural health CAH eligibility requirements, and agreements often include transfer arrangements, quality assurance, physician review, credentialing, and specialty clinic staffing.

Laboratory and Radiology

Nearly a quarter of CAHs expanded their laboratory and radiology services. Virtually all CAHs had these services prior to conversion. Although our survey did not collect details on these expansions, it is likely that many of these expansions involved capital expenditures for new equipment, as well as physical remodeling. Our site visits confirm that many CAHs made such investments. How were small hospitals that have had negative margins for several years able to make such investments? One likely explanation is the new opportunity to recover capital costs through cost-based reimbursement. Some of these capital needs are relatively small (especially some lab equipment), and may have been funded by loans. With the assurance that cost-based reimbursement would help recover the costs (for all Medicare and, in some states, Medicaid procedures), post-CAH loans may have been easier to secure, even for hospitals with chronic negative margins. In addition, hospitals may have used lease arrangements for equipment, again, building the cost into cost-based reimbursement.

Home Health

The service most commonly eliminated was home health. Although the divestiture of a home health service has occurred approximately concurrent with CAH conversion for 24 survey respondents, the only connection we would infer between the two strategic moves is that, in considering conversion, hospitals engage in scrutiny of their financial condition. They were likely to find that, under the interim home health payment system prompted by the 1997 Balanced Budget Act, and facing imminent prospective payment, home health was going to be a money loser. Nevertheless, thirteen hospitals expanded their home health services in the CAH conversion year. Considering the uncertain future for home health reimbursement, these thirteen home health expansions may be evidence that home health offers a staffing "buffer" that allows RNs, LPNs and certified nurse aides (CNAs) to be flexibly scheduled among services, achieving a kind of staffing efficiency that offsets the poor reimbursement projections. Or perhaps hospitals are meeting a community service need despite revenue problems.

Obstetrics

Relatively few CAHs (27%) offered obstetric services, despite evidence from rural health research centers that low-risk rural women have better outcomes if they deliver close to home.2-4 A variety of conditions have made providing obstetrical (OB) services a significant challenge for most small rural hospitals, including physician coverage, surgical backup, and sufficient volumes. 

Next to home health, this is the service most likely to have been dropped after CAH conversion: 17 hospitals (9%) dropped their OB service, and two more limited services. While 58 percent of CAHs overall are 30 or more miles from the next hospital offering OB, 63 percent of those hospitals that dropped or limited services were at least 30 miles away, and almost a third of those that dropped or limited services were 45 or more miles from the next facility. Of those who dropped or limited services, two-thirds were considered "isolated" by Rural Urban Commuting Area (RUCA) code designation.*  Of the majority of CAHs not offering OB service, 28 percent (or 40 hospitals) were 45 or more miles from the next facility. 

Most of the rural hospitals we visited that are continuing to offer OB service in the face of the financial and logistical odds, serve a primarily low-income population. A couple of these hospitals are on Indian reservations. When Medicaid offers cost-based reimbursement to CAHs (such as in Montana and Oregon), the high cost of maintaining these services is recoverable. In other cases (such as Missouri and New Mexico), hospitals face the more serious financial consequences reflecting the fact that square feet dedicated to OB are not allowable on the Medicare cost report. At least one of the hospitals we visited was considering dropping OB for that reason.

Changes in Surgical Volume

While 12 percent of hospitals dropped or limited inpatient surgery (N=26), and 8 percent hospitals (N=18) dropped or limited outpatient surgery at the time of conversion, a large majority of hospitals expanded or maintained their surgical services, especially in the outpatient setting. We did not collect data on specific procedures that are offered. 

Of the 91 CEOs (48%) responding to our survey who said they "expected a change in surgical services" over the next few years, only two said there would likely be a decrease. Twenty-one of 93 CEOs (23%) said they were recruiting a surgeon.

Of those who dropped or limited inpatient surgery following conversion, almost a third (8 hospitals) were 45 or more miles from the next facility offering inpatient surgery. Of the hospitals that dropped or limited outpatient surgery, only 11 percent (or 2 hospitals) were that far away from the next facility offering the service. Seven hospitals (41%) that dropped or limited outpatient surgery were considered isolated (RUCA code 10 or greater).

A third of hospitals that perform no inpatient or outpatient surgical services (for a total of 14 hospitals) were 45 or more miles from the next facility offering any surgery.

Of note, hospitals receiving local tax support were less likely to drop surgical services: for inpatient surgery, 38 percent of those that dropped or limited the service got tax support, while 62 percent of those that dropped the service did not (p=.12). On the outpatient side, 28 percent of the hospitals limiting or dropping surgery got tax support, versus 72 percent who did not (p=.025).

We also asked about the number of inpatient and outpatient procedures performed per year, before and after conversion to CAH. Since a few CAHs had extremely high or extremely low surgical volume, we grouped hospitals into seven surgical volume categories to compare pre- and post-conversion outpatient surgical volume (Table 2).

Table 2. Outpatient Surgical Procedures per Year. 
Pre-conversion vs. Post-conversion

(Cells indicate the number of hospitals reporting surgical volume 
in the indicated ranges both pre- and post-CAH conversion. n=135)

pre-CAH
procedure volumes
 

post-CAH conversion procedure volumes 

<50 procedures/ yr

50-74

75-99

100-199

200-299

300-399

400 +

<50
procedures/
yr

15
hospitals

6

0

1

0

0

0

50-74

 

5

5

2

2

0

0

0

75-99

 

1

0

3

1

0

1

1

100-199

 

2

0

0

20

3

2

0

200-299

 

1

1

0

1

11

5

4

300-399

 

1

0

0

0

1

6

9

400 +

 

1

0

0

0

0

1

2 3

Table 2 provides an illustration of the number of hospitals** that increased, decreased, or held constant their outpatient surgical volume. The shaded diagonal indicates those hospitals without a substantial change in volume (n = 83). All cells to the left and below the diagonal count hospitals that decreased their volume as they converted to CAH status (n= 15). Those cells to the right and above the diagonal count hospitals that increased their volume (n=37). While this analysis indicates more hospitals increased outpatient surgical volume than decreased it, the dominant category is those facilities whose volume stayed essentially the same. 

The Influence of Network Affiliation

As mentioned above, it is tempting to infer from the expansion of certain services that CAHs have been able to expand with the help of their network affiliations. Our survey offers mixed evidence on this question. Only fifty-one responding hospitals (23.5%) indicated that their affiliated hospital had played a major role in accomplishing any of the service changes since conversion to CAH. However, scrutiny of scope of services responses from these 51 hospitals indicates that network affiliation may have made a difference (Table 3). 

Table 3. Scope of Services of Critical Access Hospitals where 
the Affiliated Hospital Had a Role in Service Changes
(n=51, % in parentheses)

SERVICE

HAD SVC PRE-CAH

EXPANDED SVC WITH CAH CNVSN

ADDED SVC SINCE CAH CONVERSN

HAVE SERVICE NOW

DROPPED SINCE CAH CONVERSN

INPT SURGERY

29 (57)

6 (12)

2 (4)

29 (57)

2 (4)

OB

14 (27)

1 (2)

2 (4)

10 (20)

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