Thanks for developing this policy in response to Budget Bill Item 28 WWWW and 12VAC30-80-25:B.1.  We generally agree with most of this policy but request you consider the following and make related changes.

1. Please clarify the term "fiscal year" to clearly indicate the time; current language could mean the fiscal year used by FQHCs or DMAS and is unclear.
2. We request that the timeline of 180 days shown on page 4 be shortened to no more than 90 days.  The financial strain on FQHCs already is onerous with expenses having been incurred for a year.
3. Actions by the General Assembly resulted in DMAS allowing FQHCs to submit a change in scope documentation in late 2024 prior to publication of instructions for preparation of this submission, including listing what prior changes in scope would qualify.  Tri- Area earlier this year submitted documentation for adding a service, but we had been told that adding sites would not qualify.  Now under the DMAS final instructions we find that our four new sites are eligible, and we request that we be allowed to submit additional documentation to add these to the scope changes.

DMAS has been out of compliance for over 20 years resulting in underpayments to FQHCs.  FQHCs should compensated for this entire period and request payment for these unreimbursed costs in accordance with applicable federal law.  The ability of FQHCs to serve our patient communities depends on adequate and timely compensation.

In accordance with applicable legislation, we request timelines for Change in Scope filings, determination and appeals processes reflect what is achievable and that these be reasonably expedited.