Critical access hospitals are an entirely different kettle of fish. I'm somewhat familiar with the CAH rules (I worked as a surveyor for my state and CMS for several years, and we had a few CAHs that we surveyed), and I know that CAHs aren't even required to have an RN in the house 24 hours/day -- just one shift, and they can just have an RN on call the rest of the time. So I wouldn't look for much help from "the rules." (On the other hand, I've never heard of a CAH having an ICU -- maybe that's part of the problem.) The whole point of CAHs is that they're held to a lower standard than other hospitals because they wouldn't be able to meet the "regular" rules/regs/standards and it would be a real hardship for the community (because of the distance to the next hospital) if they had to close.