Oregon Office of Rural Health

CMS Relaxes Policy on Emergency Drugs and Biologicals for RHCs

The National Association of Rural Health Clinics (NARHC) is happy to report that CMS is significantly altering their guidance policy regarding emergency drugs and biologicals required in Rural Health Clinics (RHCs). This change is effective immediately.

Previously, RHCs were required to stock drugs and biologicals from each of the following categories:

  1. Analgesics;
  2. Local Anesthetics;
  3. Antibiotics;
  4. Anticonvulsants; and
  5. Antidotes, emetics, serums & toxoids.

However, as of September 3rd, 2019, RHCs will only be required to consider each category when they craft their written policies. This means that RHCs will not be required to stock snake antidote, emetics, or anticonvulsants! Here is the key line from the new policy:

While each category of drugs and biologicals must be considered, all are not required to be stored…

We will still be required to store drugs and biologicals for emergencies, but now, CMS is allowing us to determine which drugs and biologicals are most appropriate for our communities:

…when determining which drugs and biologicals it has available for purposes of addressing common life-threatening injuries and acute illnesses, the RHC should consider, among other things, the community history, the medical history of its patients and accepted standards of practice. The clinic should have written policies and procedures for determining what drug/biologicals are stored and that address the process for determining which drugs/biologicals to store, including identifying who is responsible for making this determination.

NARHC has been advocating for this change ever since the January 2018 revision to the State Operations Manual Appendix G was released implying that all RHCs needed to buy costly snake anti-venom. We believe that these changes from CMS will provide meaningful regulatory relief and save money. While this may not have been fixed as fast as we had hoped, we must thank CMS for listening to and addressing our concerns.

You can read the full Appendix G revision memorandum here: Read More