+--------------------+------------------------+------------------------+
| ![](media/imag     | **Colville Medical     | **Garden Homes         |
| e1.png){width="1.9 | Center**               | Specialty Clinic**     |
| 645833333333333in" |                        |                        |
| height="0.75       | **(509) 684-3701**     | **(509) 684-3701**     |
| 06944444444444in"} |                        |                        |
|                    |                        |                        |
| 1**200 East        |                        |                        |
| Columbia St.**     |                        |                        |
|                    |                        |                        |
| **Colville, WA     |                        |                        |
| 99114**            |                        |                        |
+--------------------+------------------------+------------------------+
|                    | ##                     | **Garden Homes         |
|                    |                        | Physical Therapy**     |
|                    | ## Kettle Falls Clinic |                        |
|                    |                        | **(509) 685-5888**     |
|                    | **(509) 738-6607**     |                        |
+--------------------+------------------------+------------------------+

July 28, 2008

CMS

Department of Health and Human Services

P. O. Box 8010

Baltimore, MD 21244-8010

Regarding: CMS 1910-P2 \_\_ Comments

Dear CMS:

Comment 1: Rural Health Clinics should be eligible for 340B pharmacy
programs. The 340B Drug Pricing Program resulted from enactment of
public Law 102-585, the Veterans Health Care Act of 1992, which is
codified as Section 340B of the Public Health Service Act. Section 340B
limits the cost of covered outpatient drugs to certain entities
including federally qualified health clinics (FQHC) and FQHC
look-a-likes but not rural health clinics (RHC). FQHCs and RHCs care for
the same population groups but RHCs are not eligible for the 340B Drug
Pricing Program. The 340B pricing program here at NEWMG would bring
access to low cost prescriptions to low-income residents of Stevens
County.

Comment 2: RHC reimbursement rate should be raised. Rural Health Clinics
are reimbursed less than Community Clinics (FQHC) for exactly the same
medical services. We serve the same population and for NEWMG, we have a
sliding scale we use to help patients without the ability to pay receive
medical services in our RHC offices just like FQHCs. The Per Visit
Payment limit should be raised or better yet, eliminated as it is for
Hospital RHCs.

Comment 3: The Proposed rule adds unfunded mandates to the RHC program.
The proposed rule adds QAPI programs and requires added infection
control programs but does not add reimbursement to fund the programs.
The Per Visit Payment Limit should be raised so RHCs can pay for these
new requirements or better yet, the Per Visit Payment Limit should be
eliminated as it is for Hospital RHCs.

Please be sure to contact me should you have questions regarding my
comments.

Regards,

Dr. Ronald G. Rehn, DHA, CPME

Chief Executive Officer