Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
Guidance Document Change: Federally Qualified Health Center (FQHC) Change in Scope Policy
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12/18/24  9:41 am
Commenter: Greater Prince William Community Health Cener

Greater Prince William Community Health Center - PPS Change in Scope
 

For over 18 years, Greater Prince William Community Health Center has been providing health care services to the underserved residents of Prince William County.  GPWCHC has added services and sites to meet the most critical healthcare needs of our community. From tripling the number of centers to adding behavioral health, dental, OB-GYN and physical therapy services to implementing a patient transportation program, GPWCHC has been responsive to the needs of over 23,000 patients who have over 86,000 annual visits. This has not come without additional cost which the current  Medicaid reimbursement methodology inadequately covers for Medicaid recipients.  GPWCHC has to subsidize its care to Medicaid recipients with grants and other patient service revenue, but even then GPWCHC has less than a week of cash on hand and has an operating loss. 

With over 88% of our patients living 200% and below the federal poverty level and 52% of our patients with Medicaid, the urgent need to expand sites and services is critical.  We have patients who need access to urgent care, infectious disease care and family planning services along with case management and care coordination.  The costs to provide these services has outpaced VA's out-of-date and non-compliant Medicaid reimbursement methodology. GPWCHC is unable to expand to meet the needs of our community.

The regulation 12VAC30-80-25:B.1 outlines that beginning October 1, 2001,and for each fiscal year thereafter, each Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) should receive a per-visit payment adjusted annually based on the Medicare Economic Index (MEI) for primary care services.  The reimbursement should also account for any changes in the scope of services offered by the center.   For over 20 years, Virginia health centers have not received this fair and reasonable compensation for the services we provide to Medicaid recipients.  This chips away at the strength of the state’s healthcare safety net, weakening the system and ultimately negatively affecting patient outcomes and increasing the state’s cost of providing care to Medicaid recipients.  When FQHCs do not provide the kinds of primary care services necessary to keep people healthy and productive, patients go to more expensive venues of care (i.e. emergency departments, urgent cares) or delay needed care until the patient is sicker and more costly to treat.

After more than 20 years of waiting and in compliance with item 288 WWWW, Greater Prince William Community Health Center, a Virginia FQHC, respectfully requests the implementation of this policy, along with the new PPS rate, effective January 1, 2025. We also request reimbursement for any unreimbursed costs incurred prior to the submission in accordance with applicable federal law. In keeping with the applicable legislation, we would like to respectfully request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

 

CommentID: 229021