Thank you for developing this policy in response to Budget Bill Item 28 WWWW and 12VAC30-80-25:B.1. We understand and agree with most of the document. However, we have a few points for consideration.

1. In several places, there is a reference to a “fiscal year”. Whose fiscal year? The FQHC’s or DMAS’s? That needs to be clear on pages 2 and 3. Everything is dependent on this timeline.
2. On page 4 DMAS indicates a decision will be made within 180 calendar days. This is a bureaucratic delay at its worst. FQHCs have thin margins given the clients they serve. Waiting six months puts undue pressure on them. Given the technology today, this review should be processed in much shorter timeframes.
3. DMAS allowed FQHCs to submit a change in scope documentation in late 2024. This guidance was not in place at that time. DMAS should allow FQHCs to submit additional documentation for prior changes in scope to align practice with policy for the greatest efficiency, effectiveness, and equity.

Finally, DMAS was out of compliance for over 20 years, resulting in significant underpayment for FQHCs. FQHCs should receive payment for any unreimbursed costs from the past 20 years to bring Virginia into compliance with applicable federal law.