• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, Blue Ridge Medical Center 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.

After more than 20 years of waiting and in compliance with item 288 WWWW, Blue Ridge Medical 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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) 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.

After more than 20 years of waiting and in compliance with item 288 WWWW, Bland County Medical Clinic (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.

Change in Scope

• • 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
     
  • Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, Johnson 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.

As outlined in 12VAC30-80-25:B.1 & Budget Bill—HB6001, Change-in-Scope Requests must be processed in a timely Manner. 

In compliance with Item 288 WWWW, I respectfully request the implementation of this policy, along with the new PPS rate, effective January 1, 2025.

I also request that the FQHC's in Virginia receive reimbursement for any unreimbursed cost incurred before the submission, per applicable federal law. 

12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
 

Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, Shenandoah Community Health 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.

12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.

Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, Southwest Virginia Community Health Systems, Inc. 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.

After more than 20 years of waiting and in compliance with item 288 WWWW, Southwest Virginia Community Health Systems, Inc., (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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

After more than 20 years of waiting and in compliance with item 288 WWWW, Central Virginia Health Services, Inc. (CVHS), (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.

Respectfully submitted, 

Paula Tomko

Chief Executive Officer

Central Virginia Health Services, Inc.

After more than 20 years of waiting and in compliance with item 288 WWWW, Martinsville Henry County Coalition for Health and Wellness (dba Connect Health + Wellness), (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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfully submitted, 

Marcus Stone

Chief Executive Officer

Martinsville Henry County Coalition for Health and Wellness

Cenevia supports DMAS’s efforts to issue a written FQHC Medicaid change in scope policy to support health center efforts to seek rate adjustments.

The proposed Policy appropriately acknowledges that changes in the “type, intensity, duration or amount of services” may trigger changes in scope consistent with CMS guidance from 2001.  The list of qualifying events for a possible change in scope should include language explicitly stating that the list is provided by way of example and meant to be non-exhaustive. The example stating that a qualifying event includes “a change in intensity, type, or duration of a service resulting from federal or state regulatory requirements specific to FQHCs” is unduly narrow. First, the omission of “amount” of services is inconsistent with 2001 CMS guidance that includes changes in the amount of services. Second, the example provided excludes changes in intensity, type, duration, and amount of services that do not stem from explicit federal or state regulatory requirements and are simply changes stemming from improved/best practices or changes/modernizations in health services delivery.  Limiting the federal or state regulatory requirements to just those that apply specifically to FQHCs is also unduly narrow because there may be changes that apply to numerous health care provider types, not just FQHCs, that FQHCs will have to comply with.

It is unclear whether the Policy seeks to isolate only the incremental cost of the qualifying event in providing, “The change in scope may result in an increase or decrease of the Medicaid base rate, depending on the total allowable costs attributable to the change in scope.” This language appears to focus on just the incremental cost associated with the change. However, in the next paragraph the Policy provides that, “The new Medicaid PPS base rate will be calculated using the provider’s reasonable total allowable cost of furnishing core and non-core covered services divided by the total number of encounters for the change in scope year.” This language is consistent with the all inclusive rate calculation methodology contemplated by the Medicaid cost report and implicitly acknowledges the difficulty that attempting to isolate the incremental costs associated with implementing a proposed qualifying event would entail. We suggest that the Policy be revised to eliminate the language “depending on the total allowable costs attributable to the change in scope” to eliminate the possibility of an incremental approach to the rate adjustment process.  

The requirement that implementation of the qualifying event will need to take place for a full fiscal year, is mitigated somewhat by the fact that the Policy contemplates the submission of interim change in scope requests in accordance with Section 3. The other mitigating factor is that if the qualifying event is established then the approved PPS rate will be made retroactive to the date the change was implemented. That retroactivity somewhat mitigates against the length of time processing the rate adjustments will take. Both the interim request option and the retroactivity element should be considered material elements of the Policy that are retained as the Policy is finalized.  The time period to review and either approve or deny the request should be reduced from 180 to 90 days.

The Policy appropriately incorporates administrative appeal rights that are then subject to judicial review if a provider is dissatisfied.

As an individual who has been involved with FQHCs for over 20 years, it is nice to see this process being put in place.  I have personally witnessed the demand for expanded services to meet the needs of the Medicaid beneficiaries.  More staff has been added to address psychiatric issues, social determinants of health and substance use disorders.  In addition, Virginia FQHCs often were the site for the most COVID testing and vaccination in their communities.  But it has not come without cost.  Many of the supporting positions are not billable services but are critical to navigating the health system for Medicaid beneficiaries.  Cost of supplies and salaries for the professionals who care for the Medicaid population has gone up tremendously over the years but the reimbursement for these services has not.  The FQHCs are dedicated to preventative and primary care for the VA Medicaid population and should be reimbursed accordingly.  Therefore I support these bills to ensure FQHCs are able to continue to provide the needed services for Medicaid.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) 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.YU

After 27 years in healthcare, I moved from the private practice/medical group sector to the world of FQHCs.  Daily, I am amazed at the tremendous work done to partner with our patients to promote health and heal illness - all while working to address the many barriers to achieving better health.  We have team members focused not only on physical health but mental health, food insecurity, housing, and medication costs - to name just a few.  FQHCs are known for providing high-quality, cost-effective care but our costs of rendering these important services continue to climb.  Reimbursement for services has not risen to match the rising cost of doing business.  Without a process to demonstrate the scope of our services and seek additional compensation for these services, centers will be forced to reduce or eliminate critical programs for our communities.

After more than 20 years of waiting, and in compliance with item 288 WWWW, Healthy Community Health Centers, located in Harrisonburg, 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

Sincerely,

Natalie Bass, BSN, RN

Executive Director

We support the Change in Scope for FQHCs as outlined below.  We respectfully ask that these changes be implemented and in addition, ask for the timely processing of change-in-scope requests within 90 days.

12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.

Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. 

We have waited for more than 20 years for this change and now, in compliance with item 288 WWWW, the Community Health Center of the New River Valley (a Virginia FQHC) 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.

FQHC Change in Scope

After more than 20 years of waiting and in compliance with item 288 WWWW, Clinch River Health Services, Inc., a Virginia FQHC, respectfully requests the implementation of this policy, along with the new PPS rate, effective January 1, 2025. We also respectfully request reimbursement for any unreimbursed costs incurred prior to the submission in accordance with applicable federal law.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) 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.

Respectfully submitted,

Gary Gilliam

Chief Executive Officer

Clinch River Health Services, Inc.

After more than 20 years of waiting and in compliance with item 288 WWWW, Horizon Health Services, Inc., 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.

Community Health Centers are a lifeline to so many underserved patients in Virginia. Health systems such as ours and many more across the state truly address all patient needs, often going outside the 4 walls of the exam room to help patients with any barriers to care that they may face. This includes transportation, language needs, medication assistance, behavioral health needs and so much more. We ask that reimbursement rates be evaluated annually in a manner that will account for time and complexity of services rendered.

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfully,

Kimberly B. Sadler, CEO

Horizon Health Services, Inc.

After more than 20 years of waiting and in compliance with item 288 WWWW, the Rockbridge Area 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 before the submission in accordance with applicable federal law.

FQHCs are a lifeline to so many underserved Virginians.  Health systems like ours truly address all patient needs, including the barriers they face (such as transportation, language and literacy, medication assistance, and behavioral health needs) in accessing health care services.

In keeping with the applicable legislation, we respectfully request that any timelines associated with the Change in Scope filing, determination, or appeals process be achievable and timely.

• 12VAC30-80-25:B.1 - Reimbursement for federally qualified health centers (FQHCs)and rural health clinics (RHC): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into accountant increase or decrease in the scope of services by the FHHC/RHC during its fiscal year.
• Budge Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfull submitted,

Suzanne Sheridan, CEO

Rockbridge Area Health Center

After more than 20 years of waiting and in compliance with item 288 WWWW, Southern Dominion Health System, 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.

Community Health Centers are a lifeline to so many underserved patients in Virginia. Health systems such as ours and many more across the state truly address all patient needs, often going outside the 4 walls of the exam room to help patients with any barriers to care that they may face. This includes transportation, language needs, medication assistance, behavioral health needs and so much more. We ask that reimbursement rates be evaluated annually in a manner that will account for time and complexity of services rendered.

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfully,

Lucy J Elder

Executive Director 

Stony Creek Community Health Center

After more than 20 years of waiting and in compliance with item 288 WWWW, Daily Planet Health Services (a Virginia FQHC and Healthcare for the Homeless Grantee) 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. DPHS has seen the cost to provide high quality care increase each year as we work to meet our communities' needs. 

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Eastern Shore Rural Health System, Inc. (ESRHS) submits these comments on a matter of great consequence to community health centers. The timely processing of change-in-scope requests within 90 days is critical to Federally Qualified Health Centers (FQHCs) like ours. Two items relevant to this request are cited below.

• 12VAC30-80-25:B.1-Reimbursement for FQHCs and rural health clinics (RHCs): Beginning Oct. 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than Jan. 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Beginning in May 2020 ESRHS has focused on adding more locations to increase access to care in our region. We opened Eastville Community Health Center, a new larger state-of-the-art facility that brought digital X-ray and behavioral health care to Northampton County, these services were previously unavailable. Additionally, new oral care access points for Medicaid beneficiaries were opened at our Eastville center and Nandua Middle and Kiptopeke Elementary Schools. In 2023 we added an urgent care site that allows Medicaid beneficiaries to receive care for issues that might have otherwise landed them in the ER. During this time, we also added behavioral health care services to Eastville, Onley and Atlantic Community Health Centers. Uncompensated care continues to grow due to the lack of ability to submit a change in scope. Our calculations show that over the last three fiscal years ESRHS has provided $1,245,710 in uncompensated care while these additional services resulted in 84,000+ patient visits.

After more than 20 years of waiting and in compliance with item 288 WWWW, ESRHS, 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.

Respectfully, Jeannette Edwards CEO

After more than 20 years of waiting and in compliance with item 288 WWWW, Southern Dominion Health System, 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.

Community Health Centers are a lifeline to so many underserved patients in Virginia. Health systems such as ours and many more across the state truly address all patient needs, often going outside the 4 walls of the exam room to help patients with any barriers to care that they may face. This includes transportation, language needs, medication assistance, behavioral health needs and so much more. We ask that reimbursement rates be evaluated annually in a manner that will account for time and complexity of services rendered.

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfully,

Albert Brogan

Chief Financial Officer

Community Health Center of the New River Valey

Good morning;

After more than 20 years of waiting and in compliance with item 288 WWWW, Johnson Health Center 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.

Community Health Centers are a lifeline to so many underserved patients in Virginia. Health systems such as ours and many more across the state truly address all patient needs, often going outside the 4 walls of the exam room to help patients with any barriers to care that they may face. This includes transportation, wrap-around services to connect community dots, language needs, medication assistance, behavioral health needs and so much more. We ask that reimbursement rates be evaluated annually in a manner that will account for the time and complexity of services rendered. In light of the recent events involving the killing of a healthcare CEO, the work that health centers do eases the frustration already present in a challenging healthcare environment. I encourage you think deeply on this when evaluating the importance here. 

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Sincerely,

Gary Campbell

President and Chief Executive Officer

As a practicing OB/GYN and CEO for a Federally Qualified Health Center, I have personally witnessed the demand for expanded services to meet the needs of the Medicaid beneficiaries.  More staff have been added to address the increasing needs of health center patients including psychiatric issues, social determinants of health and substance use disorders.  In addition, Virginia FQHCs answered the call and provided extensive support of  the COVID response including COVID testing and vaccination in their communities.  But it has not come without cost.  Many of the supporting positions are not billable services but are critical to navigating the health system for Medicaid beneficiaries.  The escalating cost of supplies and salaries for the professionals who care for the Medicaid population has not been matched by the reimbursement for these services.  The FQHCs are dedicated to preventative and primary care for the VA Medicaid population and reimbursement needs to reflect this.  Therefore, I support these bills to ensure FQHCs can continue to provide  quality healthcare  service for our Medicaid patients.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, HealthWorks for Northern Virginia, 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.

I am a staff member at HealthWorks for Northern Virginia. Through my work, I have seen the demand for expanded services to meet the needs of the Medicaid beneficiaries. Like many centers, HealthWorks has added staff to address the increasing needs of our patients, including psychiatric issues, social determinants of health, and substance use disorders. In addition, Virginia FQHCs provided extensive support during COVID pandemic, including COVID testing and vaccination in their communities.

But doing our part has not come without challenges. Many of the supporting positions required to support these expanded services are not billable, but they are critical to navigating the health system for Medicaid beneficiaries. Additionally, the escalating cost of supplies and salaries for the professionals who care for the Medicaid population has not been matched by the reimbursement for these services. FQHCs are dedicated to preventative and primary care for the VA Medicaid population, and reimbursement needs to reflect this. Therefore, I support these bills to ensure FQHCs can continue to provide quality healthcare services for our Medicaid patients.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb) (3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, HealthWorks for Northern Virginia, 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.

Thank you,
Anna Smith
Director of Communications and Development
HealthWorks for Northern Virginia

I am a staff member at HealthWorks for Northern Virginia. Through my work, I have seen the demand for expanded services to meet the needs of the Medicaid beneficiaries. Like many centers, HealthWorks has added staff to address the increasing needs of our patients, including psychiatric issues, social determinants of health, and substance use disorders. In addition, Virginia FQHCs provided extensive support during COVID pandemic, including COVID testing and vaccination in their communities.

But doing our part has not come without challenges. Many of the supporting positions required to support these expanded services are not billable, but they are critical to navigating the health system for Medicaid beneficiaries. Additionally, the escalating cost of supplies and salaries for the professionals who care for the Medicaid population has not been matched by the reimbursement for these services. FQHCs are dedicated to preventative and primary care for the VA Medicaid population, and reimbursement needs to reflect this. Therefore, I support these bills to ensure FQHCs can continue to provide quality healthcare services for our Medicaid patients.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb) (3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, HealthWorks for Northern Virginia, 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.

Sincerely,

Iman Khatib

Director of Behavioral Health

HealthWorks for Northern Virginia

I have worked with the Community Health Centers for more than 17 years and am very proud of the services we provide to the most vulnerable populations who most of the time have very few options to seek health care. Due to the limited income resources, those patient populations often ignore the health issues which then turn into chronic conditions and increase ER visits. FQHCs are so vital for the Health Systems and play an important role in keeping the overall costs low by providing preventive care and routine services.

At Loudoun Community Health Center, we have expanded our medical care from 2 sites to 5 sites, added additional dental location, now provide mammogram and ultrasound services as well, which has added to our cost tremendously, but there has been no to little PPS increase in last 20 years. The PPS rate we have is far from our actual costs of providing services. With the most recent inflation rate, it is becoming almost impossible to run the services at the current level.

Therefore, I support these bills to ensure FQHCs can continue to provide quality healthcare service for our Medicaid patients.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, HealthWorks for Northern Virginia, 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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, Kuumba Community Health & Wellness Center, Inc. d/b/a New Horizons Healthcare, 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.

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. Asa result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

Respectfully submitted, 

James Werth, Jr., PhD, ABPP

I am a board member at Rockbridge Area Health Center (RAHC) in Lexington VA. In my time on the board, the demand for expanded services to meet the needs of the Medicaid beneficiaries has grown. We have added staff to address the increasing needs of our patients, especially to meet the behavioral health needs as well as physical health. 

The ever increasing cost of supplies and salaries to meet the needs of the Medicaid population has not been matched by the reimbursement for these services. Please make certain that we can continue our services and meet the increasing needs of the populations we serve.

1. 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics(RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
2. Budget Bill-Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C.1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) respectfully requests the implementation of this policy, alongwith the new PPS rate, effective January 1, 2025. We also request reimbursement for any unreimbursed costs incurredprior to the submissionin accordance with applicable federal law.

After more than 20 years of waiting and in compliance with item 288 WWWW, RAHC (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.

After more than 20 years of waiting and in compliance with item 288 WWWW, Rockbridge Area 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.

As an employee at Rockbridge Area Health Center (RAHC) in Lexington, VA, I've seen firsthand how the demand for expanded services, particularly to meet the needs of our Medicaid beneficiaries, has significantly grown during my time here. To address these increasing demands, we've had to add more staff. 

Additionally, the rising costs of supplies and salaries necessary to serve our Medicaid population have not been met by corresponding reimbursement rates for these services. It’s crucial for us to ensure that we can continue providing high-quality care and meet the growing needs of the communities we serve.

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.

In light of this, we are asking for the Department of Medical Assistance Services (DMAS) to implement a process, as required by the Budget Bill-Item 288 WWWW, no later than January 1, 2025, to allow FQHCs to notify the department of changes in the scope of services we offer. Additionally, we request reimbursement for any unreimbursed costs incurred prior to this submission, as outlined by federal law.

re: FQHC Change in Scope

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. Asa result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

FQHC Change in Scope

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. As a result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

Sincerely,

Sonita Harris

Community Board Member

Tri-Area Community Health

FQHC Change in Scope

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. Asa result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

FQHC Change in Scope

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. Asa result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

Jana Pobrislo

Tri-Area Community Health Board

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 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. That is 6 months. There is no need for it to take more than 90 days. There is not a lot of data to review. And, the FQHC has already been incurring these expenses for a year. The longer the review takes, the more financial strain the FQHC continues to absorb.
3. In response to the actions by the General Assembly, DMAS allowed FQHCs to submit change in scope documentation in late 2024. However, the proposed policy obviously was not in place when this documentation was being prepared and submitted. Asa result, FQHCs were not given official directions about what would serve as qualifying events. We therefore believe that DMAS should allow FQHCs an opportunity to submit additional documentation for prior changes in scope that would qualify under the current policy.

     As a specific example, earlier this year, Tri-Area only submitted documentation for adding a service. We did not provide anything for additional sites because we were told that the interpretation of the DMAS guidance at the time was that adding a site would not qualify as a change in scope. However, the current document clearly would allow new sites to be considered changes in scope that could lead to an increase in the PPS rate. Therefore, Tri-Area will not be receiving the PPS increase we deserve because we did not know we could submit documentation for the 4 sites we added from 2020-2023.

Finally, DMAS was out of compliance for over 20 years. That is 20 years of underpayment for FQHCs. FQHCs should be made whole for the entire time that DMAS was out of compliance. We therefore request payment for any unreimbursed costs incurred prior to the current submission in accordance with applicable federal law.

In keeping with the applicable legislation, we request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) 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.

After more than 20 years of waiting and in compliance with item 288 WWWW, Portsmouth Community Health Center, Inc., (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

 I have served for over 7 years on the BOD and the Finance Committee for Rockbridge Area Community Health Center and have seen first hand the improvement in community health that this center has promoted.   Over the past several we have provided an average of 35,000 visits/year, the majority of which are Medicaid patients that would otherwise have a very difficult time accessing medical care as many local private practices do not accept Medicaid patients.    Additionally, over the past several years we have expanded from 2 sites to 9 sites in order to improve access to care for this vunerable population.   The financial burden of providing this care is overwhelming as we need to compete for qualified providers by offering competitive saleries and benefits and the cost of supplies continues to increase every year.  In short;  we are asked every year to do more with less and there comes a point where that is just not possible.    We need to be fairly compensated for our Medicaid visits with a fair PPS rate.                                                                                                 The regulation 12VAC30-80-25:B.1 outlines theat 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 offfered by the center.                                                    In light of this, we are asking for the Department of Medical Assistance Services (DMS) to implement a process, as required by the Budget Bill - item 288 WWWW, no later than January 1, 2025, to allow FQHC's to notify the department of changes in the scope of servies we offer.  Additionally, we request reimbursement for any unreimbursed costs incurred prior to this submission as outlined by Federal Law.  

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

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.

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.

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.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, (add your FQHC name) 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.

After more than 20 years of waiting and in compliance with item 288 WWWW, [Your organization] (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.

"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."

At HealthWorks for Northern Virginia, we’ve seen an increased demand for services to support Medicaid beneficiaries, including mental health care, addressing social factors, and treating substance use disorders. We’ve added staff to meet these needs, and during the COVID pandemic, we provided testing and vaccinations to our community.

However, many critical support roles aren’t reimbursed, even though they are essential for helping Medicaid patients navigate the healthcare system. Additionally, the rising costs of supplies and salaries aren’t matched by current reimbursements. FQHCs like ours are committed to providing preventative and primary care to Medicaid patients, and reimbursement must reflect that. I support these bills to ensure we can continue offering quality care.

As a staff member at HealthWorks for Northern Virginia, I have seen the increasing demand for additional services to better serve our Medicaid beneficiaries. In response to this demand, HealthWorks has increased its staff to address a variety of patient needs, including mental health care, social determinants of health, and substance use disorders. Additionally, during the COVID-19 pandemic, Virginia's FQHCs played a pivotal role in providing testing and vaccinations to local communities.

Despite our efforts to meet these needs, we face significant challenges. Many of the support positions necessary to deliver these expanded services are not reimbursed through billing, even though they are essential to helping Medicaid patients navigate the healthcare system. Moreover, the rising costs of supplies and staff salaries have not been adequately reflected in reimbursement rates. FQHCs are dedicated to providing primary and preventive care to the Medicaid population, and it’s crucial that reimbursement aligns with the cost of delivering these services. For these reasons, I fully support these bills, which will help ensure that FQHCs can continue to provide vital healthcare services to Medicaid recipients.

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.

As a Site Office Manager at HealthWorks for Northern Virginia, I have witnessed the increasing demand for healthcare services from Medicaid beneficiaries in our community. Over the past years, HealthWorks has consistently risen to meet these challenges, expanding our team to address a variety of complex needs, including medical care, psychiatric care, and dental care.

However, meeting these demands has come with significant challenges. Many essential support positions are not billable but are vital for ensuring that Medicaid beneficiaries can successfully navigate the healthcare system. These non-billable roles are crucial for improving health outcomes, yet they are not reimbursed through existing funding structures.

Furthermore, the rising costs of medical supplies and the salaries of the healthcare professionals who serve the Medicaid population have not been reflected in current reimbursement rates. This disparity makes it increasingly difficult for FQHCs to continue providing high-quality, accessible care, especially as we strive to meet the growing needs of our communities.

For these reasons, I strongly support the proposed bills that seek to increase reimbursement rates for FQHCs. These changes are essential to ensure that FQHCs can continue to provide high-quality healthcare services for Medicaid patients across Virginia, and I urge you to consider the long-term benefits that these adjustments will bring to the health and well-being of our communities.

Thank you for your consideration and continued support.

David Lopez

Herndon Site Office Manager

HealthWorks for Northern Virginia

I am a staff member at HealthWorks for Northern Virginia. Through my work, I have seen the demand for expanded services to meet the needs of the Medicaid beneficiaries. Like many centers, HealthWorks has added staff to address the increasing needs of our patients, including psychiatric issues, social determinants of health, and substance use disorders. In addition, Virginia FQHCs provided extensive support during COVID pandemic, including COVID testing and vaccination in their communities.

But doing our part has not come without challenges. Many of the supporting positions required to support these expanded services are not billable, but they are critical to navigating the health system for Medicaid beneficiaries. Additionally, the escalating cost of supplies and salaries for the professionals who care for the Medicaid population has not been matched by the reimbursement for these services. FQHCs are dedicated to preventative and primary care for the VA Medicaid population, and reimbursement needs to reflect this. Therefore, I support these bills to ensure FQHCs can continue to provide quality healthcare services for our Medicaid patients.

· 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.

· Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb) (3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process. After more than 20 years of waiting and in compliance with Item 288 WWWW, HealthWorks for Northern Virginia, 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.

Sincerely,

Mari Sanchez

Site Office Assistant Manager

Healthworks for Northern Virginia