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New Rules Will Offer A Cure To Some Of RI's Health Care Woes. What's Being Done
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OIG Issues Favorable Advisory Opinion For Community Health Centers
The HHS Office of Inspector General (OIG) issued Advisory Opinion No. 25-02 (opinion) on April 4, 2025, regarding an arrangement whereby the "requestor," a community health center (CHC), proposes, during the provision of certain social services to individuals to: identify individuals in need of primary care services; inform them of the availability of such services; and schedule an appointment for them to receive primary care services from the requestor or refer them to a local primary care provider (the proposed arrangement). Specifically, the requestor inquired as to whether the proposed arrangement, as discussed below, would warrant sanctions under Section 1128A(a)(7) of the Social Security Act (SSA) as it relates to the federal Anti-Kickback Statute (AKS); Section 1128A(a)(5) as it relates to inducements to beneficiaries (Beneficiary Inducements CMP); or the exclusion authority in Section 1128(b)(7) as it relates to the AKS and the Beneficiary Inducements CMP.
The opinion concludes that although the proposed arrangement, if undertaken, would generate prohibited remuneration under the AKS (if the requisite intent were present) and the Beneficiary Inducements CMP, the OIG would not impose administrative sanctions under the Beneficiary Inducements CMP or Sections 1128A(a)(7) or 1128(b)(7) of the SSA.
Redefining Rural Care: CHC's Approach To Health At Home
Rural and community hospitals across the country are innovating to overcome challenges like rising operational costs, geographic isolation, patient access, and outmigration. An emerging practical and transformative solution is hospital at home, which we often refer to as health at home: the ability to deliver hospital-level healthcare services directly in a patient's home.
CHC began exploring this model with a forward-thinking perspective on how rural healthcare must evolve over the coming decade. We recognized that advances in technology, combined with the growing need to improve access and outcomes, had aligned to make hospital at home both feasible and necessary. We partnered with Resilient Healthcare to offer a scalable program and co-developed technology platform that is achievable for resource-constrained rural and community hospitals.
CHC's hospital at home program focuses on three primary areas: inpatient care, outpatient therapy, and primary care at home. Inpatient services include treatment for chronic conditions such as COPD or long-duration antibiotic therapies, which can be safely managed at home under clinical supervision. Outpatient services—particularly physical, occupational, and speech therapy following surgeries—can also be delivered in the home, eliminating the need for patients in rural areas to travel long distances for care. This is especially impactful where transportation is a significant barrier. The third area, primary care at home, creates the 21st-century version of the house call—an approach that supports both chronic condition management and patient satisfaction.
While each service area is valuable, CHC found that outpatient therapy at home provides the most efficient entry point. It allows for rapid deployment without the need for federal waivers and serves as a foundation to build awareness and refine operational processes. From there, we implement inpatient and primary care offerings, always guided by the specific needs of each community and capabilities of each hospital.
The benefits of hospital at home are significant. Patients are more comfortable and engaged when receiving care in their own homes, resulting in better compliance and outcomes. Satisfaction scores improve, and access challenges—both geographic and social—are greatly reduced. Over time, we demonstrate financial value as hospitals see volume growth, reduce their reliance on traditional brick-and-mortar space, optimize staffing, and lower operational costs.
One of the most important lessons we've learned is the need for early collaboration. Hospital at home doesn't just affect internal stakeholders—it impacts primary care providers, specialists, home health agencies, and post-acute care networks. Involving these groups from the start has proven essential in building trust and ensuring a coordinated rollout.
Hospital at home is not a trend—it's a long-term evolution in care delivery. For rural and community hospitals, it represents an opportunity for organizations to meet patients where they are, deliver high-quality care more efficiently, and build a more sustainable future for healthcare.
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