RHC Certification and Conversion

Helpful Webinars on RHC Certification and Compliance

4/4/2024 We are working on a presentation for the Kansas MGMA and here are some of the resources:

  • Database of past deficiencies in Excel. Click here

  • TCT Standards can be found here

  • TCT Site Inspection List can be found here

  • Quad A RHC Standards can be found here

12/16/2023 Here are some helpful links for Rural Health Clinics:

3/28/2023 The NARHC has provided several webinars on Certification and Policies and Procedure in recent months. You can find all the Technical Assistance webinars at the following link: https://www.narhc.org/narhc/TA_Webinars1.asp

Here is the information on two of the most recent webinars that address RHC compliance:

Maintaining Compliance in Your RHC
Thursday, January 26, 2023 3 pm Eastern Time

RHC Policies & Procedures  
Thursday, October 6, 2022

December 10, 2021: Healthcare Business Specialists will have a webinar today at 1:00 PM Eastern time with Kate Hill of The Compliance Team on “How to Conduct a RHC Mock Inspection” If you have not registered for the webinar yet, here is the link: https://attendee.gotowebinar.com/register/1801076331757826829. The recording of the session, the presentation, and some additional information is provided below:


November 10, 2021

Here is a link to the Healthcare COVID-19 Health Care Staff Vaccination IFC-6 National Stakeholder Call Recording recorded November 5, 2021 regarding the requirements for all providers with a CCN number (RHCs) to vaccinate all employees with limited exceptions. Policies will have to be developed and employees vaccinated within strict deadlines. We are working on policies to comply and if you have examples to share please do so.

When becoming a rural health clinic you will receive a survey on the 9 conditions of participation to be an RHC. One of the conditions is to follow all Federal, State, and Local laws including OSHA and HIPAA. While these rules will not be specifically be surveyed in the RHC certification survey it is a good idea to update all your policies related to OSHA and HIPPA or any other Federal or State regulation.

OSHA has issued an Emergency Temporary Standard (ETS) that RHCs must comply with which can be found at the following link: https://www.osha.gov/coronavirus/ets. Medical providers must develop COVID policies and procedures (See RHC template (Word) located here) and conduct a Covid risk assessment (Template (Word) located here) as a part of compliance with the ETS.

Some sources of OSHA, HIPAA, and RHC compliance are:

May 20, 2021: Here is the information from the Preparing for the RHC Survey webinar today:

May 15, 2021: If you have not completed your HIPAA Security Risk Assessment HealthIT.gov provides a great tool to help you go through the process which can be found here.

Here is some information on HIPAA Compliance. https://www.hhs.gov/sites/default/files/ocr/privacy/hipaa/administrative/securityrule/security101.pdf

RHCs must comply with HIPAA and OSHA. Here is trusted resource for information and manuals related to OSHA and HIPAA: https://oshaguard.com/collections/hipaa

Here is more information on OSHA: https://oshaguard.com/collections/osha

Here is a short 30 minute video on OSHA compliance: https://www.youtube.com/watch?v=X3Pyld4TXFY

Here are resources for autoclaves and sterilization of instruments including forms: https://www.crosstexbms.com/resources/tools/

  • Here is an autoclave sterilization log: https://www.crosstexbms.com/media/1216/0918-ddoc00400-rev-a_sterilization-log-sheet.pdf

February 23, 2021: Many RHCs are using TCT or AAAASF to conduct the initial RHC inspections as due to Covid states are falling behind on initial RHC certification inspections. We added these resources to help you understand the expectations of TCT and AAAASF. We also updated our Evidence Binder to streamline and make it easier to assemble.

Preparing for the RHC State Inspection Webinar and Materials

On February 5, 2020 Healthcare Business Specialists presented a webinar on preparing for the state/AAAASF/TCT inspections to become a rural health clinic and re-inspections conducted by the state, AAAASF, and TCT. Here is the recording of the webinar and the PDF of the presentation:

RHC Survey Preparation Steps and Resources

As you prepare for the RHC inspection here are some resources to help you comply with the nine conditions of participation to become a rural health clinic. It is important to start acting as if you are a rural health clinic before the inspection. We have provided some resources for you to review and start working on before the Mock Inspection occurs. The Mock Inspection is designed to be educational and instructional and will elaborate on the processes and procedures that the State Inspectors, AAAASF, and The Compliance Team will expect to be in place by the time of the Certification inspection. Please click on the links below to view the documents:


Changes to the RHC Program - Fall, 2019


The Omnibus Burden Reduction (Conditions of Participation) Final Rule was finalized on September 30, 2019 and it relieves RHCs of some of the administrative burdens of the RHC status. We have webinars on October 2, 2019 and October 15, 2019 on the changes to the RHC program in the last year from a compliance standpoint.

The process to Become a Rural Health Clinic

The process to become a rural health clinic is long and will involve pulling together certain documents for various governmental entities which will review the submissions and approve them as we go along. The usual process takes between 6 months to a year to complete all five steps listed below.

  1. Preparation and submission of the 855As , State application, and deeming authority applications.

  2. Preparation for State Inspection including preparing RHC and Emergency Preparedness Policy and Procedure manuals

  3. Emergency Preparedness Training and Testing.

  4. Passing the RHC survey or responding to deficiencies in the survey.    

  5. Obtaining provider numbers for Medicare and Medicaid as well as rate setting.

Rural Health Clinic Information Resources

 We also would like to inform you of our educational resources including our Facebook Group, website, webinars, YouTube channel and seminars on RHCs. We highly recommend joining our Facebook Group as we use this to notify the 550 members about our free webinars and educational offerings by other consultants or the NARHC.

Forms from HBS to help through the Certification Process

Healthcare Business Specialists works with physician practices to convert them into rural health clinics. Here are some of the documents and questionnaires we use to get information from our clients.

CMS RHC Training Modules

On August 22, 2017 CMS published RHC and FQHC Basic Training Online Course (RFBTOC) which is a series of training modules for RHC  inspectors or new RHCs. The course will take approximately 25 hours to complete.  Rural Health Clinics (RHC) are required to comply with the Federal requirements set forth in the Medicare Conditions for Certification/Conditions for Coverage in order to receive Medicare and/or Medicaid payment. The goal of an RHC survey complaint survey is to determine whether the RHC complies with its applicable Conditions of Participation at 42 CFR 491, Subpart A. The link to find the RHC survey training course is as follows:

Startup Tools

Enrollment Information

Rural Health Clinics Center - CMS

Medically underserved areas

Rural Health Clinics must be located in a medically underserved area. The following links take you to the HRSA website with the HPSA, MUA, and MUP listings:

Health Professional Shortage Area Database         

Medically Underserved Area/Medically Underserved Population (MUA/MUP) Database