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Tag: Geographic Reclassification

Proposed Wage Index CBSA Changes

OMB proposes major changes to rural geographic areas 
Toyon Associates is pleased to provide this update on emerging reimbursement issues.  
Wage Index CBSA Update – Proposed changes to rural and urban CBSA classifications.
Issue and Background
The Office of Management and Budget (OMB) proposed significant changes that will financially impact hospitals in both urban and rural areas. If finalized, this change would alter the wage index landscape of Core Based Statistical Areas (CBSAs), which will also impact wage index reclassifications, rural redesignations under 42 CFR § 412.103, 340B thresholds and sole community hospital eligibility.  
To qualify as an urban geographic area, the OMB is proposing to increase the requirement from 50,000 to 100,000 people. This proposed change results in 144 CBSAs shifting from urban status, which based on the proposed timeline will likely start with Federal Year 2025.
Toyon’s Take | Next Steps
Stakeholders have until March 19, 2021 to submit comment. Please refer to the January 19, 2021 Federal Register, Vol. 86, No. 11 FR OMB Notice and request for comment (page 5263, OMB Recommendations (PDF version)
Please see Exhibit A (below) for the CBSAs that would change from urban to rural under OMBs proposal. Toyon is also estimating the potential financial impact of these market changes and will make our analysis available to our clients. In the meantime, please feel free to contact Ryan Sader to discuss these potential changes and related opportunities around wage index reclassifications, rural redesignation, etc. 
Contact:  Ryan Sader
888.514.9312, ext. 3240
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Postponement of FY 2022 Application Deadline to the Medicare Geographic Classification Review Board

Per requirements at section 1886(d)(10)(C)(ii) of the Social Security Act (the Act) and 42 CFR 412.256(a)(2), September 1, 2020 is the deadline to submit an application to the Medicare Geographic Classification Review Board (MGCRB) for FY 2022 reclassifications.

These provisions require applications to be filed through OH CDMS ( not later than the first day of the 13-month period preceding the Federal fiscal year for which reclassification is requested. 

Due to the COVID-19 Public Health Emergency (PHE), under the authority of section 1135(b)(5) of the Act, CMS is postponing the September 1 deadline until 15 days after the public display date of the FY 2021 IPPS/LTCH final rule by the Office of the Federal Register. See

If you have questions regarding this extension or any MGCRB data or policy issues, please direct them to CMS at

Toyon anticipates the extended deadline will be on or around September 15, 2020. To discuss this further, please contact Ryan Sader at Toyon Associates, Inc. 888.514.9312 or

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