Protecting Health Centers and Patients through Regulatory Advocacy

Once a bill is signed into law, many of the implementation details are set in place through regulations. To ensure successful implementation for community health centers (CHCs) and patients, CPCA actively engages with state and federal departments through comment letters, regulatory activities, and educational materials to influence how regulations are drafted, interpreted, or implemented. While CPCA members can view these materials addressing our top regulatory and administrative priorities through our members-only Regulatory Engagement Library, here are some highlights from the second quarter of 2024.

Department of Health Care Services (DHCS):

Alternative Payment Model (APM) Draft State Plan Amendment (SPA)
CPCA submitted two comment letters and suggested language changes to the SPA authorizing the APM. The requested changes centered on ensuring the Centers for Medicaid and Medicare Services is fully aware of the rate setting methodology and the negative impact on capitated rates that risk health centers not receiving Prospective Payment System (PPS) equivalency. 

Enhanced Care Management
In a letter to DHCS, CPCA supported DHCS’ proposal to authorize presumptive eligibility (PE) of Enhanced Care Management benefits for certain provider types. The letter also requested that DHCS include community health centers as PE entities for all populations of focus.

Street Medicine All Plan Letter
This letter outlines several requests for policy clarifications necessary for health centers providing street medicine services. In the letter, CPCA urged DHCS to clarify that any street medicine provider would be able to provide direct access to patients. Additionally, we requested that DHCS clarify which place of service codes health centers may use outside the four walls of the health center.  

Department of Health Care Access and Information (HCAI):

Response to HCAI Health Care Affordability Board Meeting
In a letter to the HCAI Health Care Affordability Board, CPCA urged the State to ensure that any investments in primary care take into account the PPS payment model for Federally Qualified Health Centers (FQHCs) and Rural Health Centers so that these crucial investments can be accessed by all Medi-Cal providers. Otherwise, the State would not be making meaningful investments in primary care. In the letter, CPCA also articulated concerns that the current APM design, particularly the impact of rate setting adjustments, will disincentivize health center adoption rather than promote widescale APM adoption resulting in the State’s inability to meet its APM adoption goals in Medi-Cal.

Health Resources and Services Administration (HRSA):

Support for Justice-Involved Individuals
CPCA submitted a letter in response to the HRSA Draft Policy Information Notice, which outlines HRSA’s position regarding health centers participating in pre-release services. CPCA drew upon our experience with the California 1115 waiver and Justice Involved Reentry Services to share recommendations that would provide clarifications on an FQHC’s responsibility to report UDS data for justice involved persons as well as on the definitions (e.g. what it means to be working “on behalf of the carcel authority”).  The letter also urged HRSA to define the universe of potential patients eligible for pre-release services.