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Health-Related Social Needs: Three Trends in Leveraging Community Partnerships

Leading health authorities have increasingly emphasized how non-medical factors such as socioeconomic status, education, employment, housing, food security, and community support have an outsized impact on health outcomes. By...more

FQHCs: Medicaid Litigation Year in Review

Recent federally qualified health center (FQHC) litigation highlights the impact state Medicaid agencies have on FQHC reimbursement. The important decisions summarized below all involve FQHC disputes over state Medicaid...more

What FQHCs Need to Know About Telehealth After the PHE

On January 30, 2023, the Biden Administration announced its intent to end the COVID-19 public health emergency (PHE) on May 11, 2023. For Federally Qualified Health Centers (FQHCs), flexibilities offered under the PHE...more

HHS Proposes to Align Federal Substance Use Disorder Law with HIPAA

Proposed changes to the federal substance use disorder law will increase provider efficiency and alignment with the Health Insurance Portability and Accountability Act (HIPAA). In a move that seeks to decrease administrative...more

FQHCs: Proposed Guidance Addresses Health Center Delivery of Telehealth Services

The federal government is requesting comments on proposed guidance for federally qualified health centers (FQHCs) that provide services via telehealth. The guidance communicates key criteria for ensuring services delivered...more

California: Health Care Providers Must Join Statewide Data Sharing Agreement by 2024

Many California health care providers, including hospitals and physician groups, will soon be required to sign on to California’s first-ever statewide data sharing agreement governing the exchange of health and social...more

CMS Requires COVID-19 Vaccination for Health Care Facility Staff

On November 4, 2021, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule that requires most Medicare and Medicaid certified providers and suppliers to vaccinate staff members within 60 days. The...more

Payment Dispute with a Medicaid Health Plan? State Not Obligated to Help, According to Federal Court

Medicaid providers cannot sue the state to seek payment from a Medicaid health plan, according to a July 9 Illinois federal district court decision. The court’s holding is likely to be a disappointment to providers...more

Congress Requires New Medicaid Payment Reporting

As part of the omnibus Federal appropriations bill enacted into law on December 27, 2020, Congress established new reporting requirements for states that make Medicaid supplemental payments. The new requirements follow on the...more

New HHS Board Will Hear 340B Drug Pricing Disputes

On December 14, 2020, HRSA established a long overdue Administrative Dispute Resolution (ADR) process that allows covered entities and drug manufacturers to bring claims against each other related to the 340B Drug Pricing...more

Patient Records: Part 2 Final Rule Reduces Substance Use Disorder Record Sharing Barriers

On July 15, 2020, a final rule revising the federal regulations governing the Confidentiality of Substance Use Disorder Patient Records (also known as 42 C.F.R. Part 2 or Part 2) was published. The revised rule will implement...more

Covid-19: CARES Act Overhauls Federal Substance Use Disorder Privacy Law

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) passed by the Senate on March 25, 2020 would make fundamental changes to the federal law, 42 U.S.C. § 290dd-2, implemented at 42 C.F.R. Part 2 that governs...more

FQHCs: Practical Impacts of Governance Requirements

This is the fourth article in our series addressing important topics for federally qualified health centers (FQHCs) and the providers who work with them. The first post in the series offered five tips for contracting with...more

FQHCs: Four Reimbursement Traps for the Unwary

This is the third article in our series addressing important topics for federally qualified health centers (FQHCs) and the providers who work with them. The first post in the series offered five tips for contracting with...more

CMS Proposes Enhanced Scrutiny over Medicaid Supplemental Payments

On November 18, 2019, the Centers for Medicare & Medicaid Services (CMS) proposed changes to federal Medicaid rules that, if implemented, would affect billions of dollars of Medicaid payments nationwide, creating new...more

FQHCs: The Nuts and Bolts of Medicaid Reimbursement

This is the second article in our series addressing important topics for federally qualified health centers (FQHC) and the providers who work with them. Our first post in the series offered five tips for contracting with...more

Five Tips for Contracting with Federally Qualified Health Centers

Partnerships with federally qualified health centers (FQHCs) are essential to serve patients in high-need areas and strengthen the social safety net. For health care providers, collaborating with FQHCs can also open the door...more

Proposed Changes to Part 2 Rules Ease Substance-Use Disorder Record Sharing

Recently proposed changes to the federal regulations governing the confidentiality of substance-use disorder patient records (Part 2) would all but eliminate the most significant and intractable barrier to sharing protected...more

California: Proposed Legislation Regulating Health Care Rates for Payors and Providers

An ambitious California proposal to regulate health care rates and curb long-term health care spending was unveiled last week in Assembly Bill 3087 (Proposed Legislation). The key concept in the Proposed Legislation is the...more

California Medicaid Agency Proposes Significant Restrictions on FQHC and RHC Reimbursement

California’s Medicaid agency has posted draft language of a new state plan amendment (SPA) that would make major changes to federally qualified health center (FQHC) and Rural Health Clinic (RHC) reimbursement. Public comments...more

SAMHSA Finalizes Second Round of Changes to Federal Substance Use Disorder Privacy Rule

New federal regulations published on January 3, 2018, clarify when lawful holders of substance-use disorder records may use and disclose patient identifying information for payment, health care operations, and audits and...more

Health Care Reform Returns to the Spotlight

Congress is now back in session and, once again, focus has turned to health care. With all eyes on returning health care reform to the forefront, a flurry of activity has sparked new legislative efforts including the...more

Ninth Circuit Victory Opens the Door to Medicaid Reimbursement Challenges Based on Equal Access Requirement

The Ninth Circuit held August 7 that the Department of Health and Human Services Secretary erred in approving a Medicaid State Plan Amendment (SPA) that cut reimbursement for outpatient hospital services in California by 10%...more

Proposed Rule Would Slash Medicare Payment for 340B Drugs

The Centers for Medicare and Medicaid Services (CMS) has proposed reducing the Medicare payment rate to hospitals for most separately payable drugs purchased under the 340B program from average sales price (ASP) plus six...more

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