CPCA Launches Regulatory Engagement Library  

Once a bill is signed into law, many of the details of how it is to be implemented are done through regulations. Accordingly, CPCA engages in regulatory advocacy, working with state and federal departments to influence how regulations are drafted, interpreted, or implemented, as a way to ensure successful implementation for community health centers (CHCs) and patients. CPCA has created a Regulatory Engagement Library (members only) that is a repository of our recent regulatory comment letters, advocacy activities, and educational materials on our top regulatory and administrative priorities. The Regulatory Engagement Library can be found here. Below are letters that have been submitted by CPCA in the first quarter of 2024. 

Department of Health Care Services (DHCS)

Equity and Practice Transformation Provider Directed Payments (EPT)
CPCA commended DHCS for standing up the program and sharing recommendations that would accelerate practice transformation and value-based care strategies for health centers. We requested more upfront information about the selection process and scoring mechanism for future EPT funding opportunities. We urged DHCS to commit to a second cohort of EPT and prioritize health centers for selection.

Enhanced Care Management Guidance (ECM)
CPCA offered feedback to DHCS on recommendations to refine the ECM benefit, including standardization of forms and maximum caseload size. We also made recommendations to move ECM to be flexible, sustainable, and not supplanted by other benefits and services.

Targeted Rate Increases (TRI)
CPCA urged DHCS to ensure that CHCs be able to meaningfully access the investments in primary care, maternal care, and mental health care through the TRI. CPCA explained that targeted rate increases should flow through a structure that allows for the payments to build on existing primary care expenditures rather than supplant existing funding, and that can be utilized by Federally Qualified Health Centers (FQHCs)/Rural Health Centers (RHCs) to increase primary care capacity rather than flowing back out during prospective payment systems (PPS) reconciliation.

Family PACT (FPACT) Certification Requirements
CPCA urged the Office of Family Planning (OFP) to mitigate issues regarding FPACT enrollment delays and streamline the site certification process. CPCA urged OFP to allow non-clinicians and PAs to be site certifiers and to state in the FPACT manual that site certifiers can delegate administrative tasks to non-clinicians. CPCA recommended that OFP allow one centralized site certifier to cover compliance among multiple sites. CPCA also requested continuity of the FPACT program when a site converts to an intermittent clinic. Lastly, CPCA requested OFP to add orientation dates and spots for providers. 

All Plan Letter to Implement the CHW Fee for Service (FFS) Benefit
CPCA highlighted the obstacles FQHCs/RHCs face in accessing the community health worker (CHW) benefit through the current PPS structure, including the lengthy process of a scope change and related CHC costs. We also asked DHCS to clarify that FQHCs can access the CHW benefit through specific programs, like Enhanced Care Management and Comprehensive Perinatal Services Programs.  Finally, CPCA requested clarifying changes to the paperwork submission requirements.  

Office of Health Care Affordability (OHCA)

Statewide Health Care Spending Target
CPCA urged OHCA to clarify how the statewide spending target will be applied to individual providers, particularly how statewide efforts to increase primary care spending, the annual Medicare Economic Index adjustments to PPS, and increased costs due to Medi-Cal Expansion and new Medi-Cal benefits and services will be factored into the statewide spending target.

Health Resources and Services Administration (HRSA)

Uniform Data System (UDS) Changes
CPCA requested that HRSA provide more clarity to health centers for both the quality-of-care measures and pregnancy intention screening in Appendix E of the UDS. CPCA also requested clarity and specification on device types for measuring blood pressure for the blood pressure quality metric. Finally, CPCA urged HRSA to amend the pregnancy intention screening question to specify which standardized screeners are to be counted.