The Consolidated Appropriations Act of 2021 establishes a Rural Emergency Hospital (REH) designation under the Medicare program. It is difficult to predict rural hospital interest in conversion to REH because conditions of participation through rulemaking and guidance have yet to be established by the Centers for Medicare & Medicaid Services. However, some first estimates of the number and type of rural hospitals that might convert to REHs will assist policymakers as they prepare for implementation of the REH model. In this study, three measures were used to predict the number of rural hospitals with 50 beds or less that are likely to consider conversion to an REH: 1) three years negative total margin; 2) average daily census (acute + swing) less than three; and 3) net patient revenue less than $20 million.