Background
Federally Qualified Health Centers (FQHCs) are designated entities in the national Health Center Program that are instrumental in providing healthcare services to underserved communities and increasing access to high quality, affordable healthcare. The fee for service model does not reimburse most providers at an adequate level to be sustainable with the growing Medicaid population and to provide the services needed to support their patient population, making enhanced reimbursement afforded to FQHCs critical to ensuring access to vital services.

In a recent article, COPE Health Solutions highlighted the value in engaging with FQHCs and discussed the four main types of these entities- see “Strategies to Maximize Medicaid Quality and Revenue”. Fully funded FQHCs receive increased Medicaid and Medicare reimbursement, but also receive some unique, key benefits, such as access to 330 Grant dollars, 340b drug pricing program participation and Federal Tort Claims Act (FTCA) coverage. To reach this level of FQHC designation, the Health Resources and Services Administration (HRSA) must open an application window for organizations to apply for FQHC Grantee status.

Opportunity
HRSA has not opened an application window, referred to as a New Access Point (NAP), since summer 2019. In the 2019 NAP, HRSA awarded over $50 million in NAP grants, funding over 77 health centers across 23 states, Puerto Rico, and the Commonwealth of the Northern Mariana Islands.

A NAP allows 1) Health Center Program participants to apply for funding for new clinic locations and 2) new organizations to apply for initial designation as an FQHC Grantee. Organizations that successfully apply for FQHC Grantee designation receive additional financial benefits, freeing up dollars to reinvest in communities, offer additional healthcare and enabling services and expand their reach in underserved areas. NAP grants are typically $650,000 annually for successful organizations.

Given that almost five years have passed since this opportunity was last made available, industry leaders are expecting additional funding to HRSA that will allow them to release a NAP.

When the next NAP is released, there are important things to consider to determine whether your organization should consider applying for FQHC designation and a NAP grant:

1. Are you serving a Medically Underserved Area or Population (MUA/P)? A key requirement for participation in the Health Center Program is to clearly demonstrate the community’s need for additional healthcare services.
2. Are you providing comprehensive primary care? FQHCs are required to provide or contract for a host of services that ensure their underserved, underinsured and uninsured patients have access to comprehensive healthcare.
3. Is your organization operating independently? Generally, to qualify for the Health Center Program, an organization needs to be an independent, 501c3 entity, that is not owned or controlled by another organization.
4. How similar is your organization’s current structure, operations and policies to those outlined in the Health Center Program Compliance Manual? FQHCs have a stringent set of requirements they must meet for eligibility in the Program. Operational changes are often required for initial designation, although some organizations are naturally more closely aligned with the compliance standards, allowing for fewer changes to be implemented in the short time frame available after application.

Anticipated Timeline
If HRSA was to release a NAP, organizations typically have two months to complete the FQHC application and an additional month to submit all required supplemental information. Successful applicants should receive notice of award approximately four months later. From the time of the notice of award, organizations will then have 120 days to ensure the clinics are open and operational and demonstrate compliance with all program requirements. During this time HRSA will complete an operational site visit to ensure the clinics are operating as depicted in the application and assess program compliance.

Given the short timeline and anticipated competitiveness of the next NAP, organizations should be preparing now to best position themselves for the application and program compliance. Our firm can provide expertise in strategic planning for the next NAP to help assess an organization’s readiness and opportunity for success in the next application.

Alternative Strategies
A NAP is not required for organizations to seek FQHC Look-Alike, Subrecipient status or Expanded Scope designation. While not all the benefits associated with an FQHC Grantee are afforded to these organization types, these three models also have clear, unique benefits for community clinics as well.

For more information on the Health Center Program, new access points, FQHC model options and engagement strategies, organizational readiness assessments or strategies for success in a NAP or FQHC Look-Alike application, reach out to COPE Health Solutions at info@copehealthsolutions.com.