Health Center Regulatory Issues

CMS Issues Several Documents of Importance to Health Centers

UPDATE:  Check out the NACHC summary of the issues impacting FQHCs in the final rule and State Health Officials’ letter here.


Last week CMS published two documents last week which will strengthen health centers’ and PCAs’ ability to protect their payment rights under Medicaid managed care. They are:

We will be providing detailed information on both of these documents in the near future. In the short term, here is a listing of key policies around PPS reimbursement that were announced in these documents:

  • Starting in July 2017, States may “delegate wrap” to MCOs only for those FQHCs that have agreed to this approach.
  • Starting in July 2017, every Medicaid and CHIP MCO will be required to contract with at least one FQHC in each service area.
  • Incentive payments made by Medicaid MCOs may not be counted against PPS payment.
  • Value-based payment (VBP) arrangements must adhere to the statutory requirements for PPS.

As we noted, more detailed information will be coming soon. In the meantime, if you have any questions please contact Colleen Meiman or Susan Sumrell.