In summer 2024, the Health Resources and Services Administration (HRSA) released a long awaited Notice of Funding Opportunity for Health Center Program New Access Point (NAP) applications allowing qualified entities to apply for Federally Qualified Health Center (FQHC) designation. It is anticipated that HRSA will award 77 grants, of up to $650,000 each, with the period of performance to begin on June 1st, 2025. This is the first opportunity to become a fully funded FQHC that has been made available since 2019, making it incredibly competitive with a very high volume of applicants anticipated.

Here are four key considerations if you applied in this round for the NAP grant to become a fully funded FQHC:

1. Successful Compliance Assessment
   The site must be open, operational, and compliant within 120 days of NAP award. Not only does this include functioning as a standard primary care practice, but also requires the site to comply with all 19 Health Center Program requirements to be assessed during an Operational Site Visit, which is to be scheduled towards the end of that 120 day window. Some of the areas often requiring the largest lift for maintaining compliance are reporting and data collection requirements, sliding fee program roll out, governance configuration, and contracting and partnerships. Compliance audits, staff training and physical site preparation are key activities to begin completing to assess any gaps and allocate resources appropriately for a successful FQHC implementation.
2. Rate Setting Strategy
   Begin preparing for your organization’s rate setting period. The first fiscal year after designation is the period in which an FQHC determines the single bundled rate for qualified services that the health center will be operating on for the foreseeable future- the Prospective Payment System (PPS) rate. Detailed financial management and oversight and appropriate budgeting are key to ensuring your organization is appropriately projecting and capturing costs during this period to receive a sustainable PPS rate. While the Health Center Program and PPS are federal statutes, there may be nuances by state in the Medicaid State Plan Amendment that may impact Medicaid rate setting, so it is important to understand whether there are any variables to consider in your state. For example, if applicable, be sure to analyze provider productivity to ensure visit thresholds are being met and projections towards the PPS rate are trending accurately.
3. Alternative Strategies
   If your organization applied for the NAP, is not awarded and is not a current participant of the Health Center Program, a possible alternative strategy is to pursue FQHC Look-Alike designation. FQHC Look-Alike applications are accepted on a rolling basis. Although FQHC Look-Alike’s do not receive the 330-grant funding of up to $650,000 annually, they are Health Center Program participants that receive many other significant benefits, including enhanced Medicaid and Medicare reimbursement and access to 340B Federal Drug Pricing Program discounts. The process of becoming an FQHC Look-Alike varies slightly from that of the FQHC grantee through the NAP, but the end goal of reaching a designation to draw down additional federal funds to sustainably serve vulnerable, at-risk communities is the same.

   COPE Health Solutions has extensive expertise in ensuring compliance with the Health Center Program requirements, FQHC rate setting procedures, and nuances of state Medicaid programs to successfully guide our clients through these pivotal moments for their organizations. Our Subject Matter Experts can help clinics get open and operational in a timely manner, ensure compliance readiness through programmatic implementation and mock site visits, and achieve financial sustainability through detailed modeling and PPS rate setting experience.

4. Value Based Care Success Enablement
   It’s critical to note that the pressure to control total cost of care (i.e. all of the medical costs for a beneficiary across the entirety of the health care continuum), while improving clinical quality and patient experience, for Medicaid, Medicare and commercial members is likely to continue to increase under the current Administration. FQHCs and FQHC Look-Alikes are well positioned to enter into value-based payment agreements with health plans, or participate in risk-based programs, such as Medicare Shared Savings Program (MSSP) ACOs and ACO REACH or the like, given their existing incentive alignment and focus on population health management and cost reduction. COPE Health Solutions is the premier value-based payment enablement firm in the country with our own market leading comprehensive population health analytics, care management, quality and HCC workflow tools that wrap around and integrate with all EMRs. We have flexible options to partner with FQHCs and other providers to improve access to premium through well-structured health plan value-based payment agreements, successful application into CMS ACO programs and the critical expertise and tools needed to succeed financially.

For more information on the Health Center Program, New Access Point grants, FQHC model options and engagement strategies, organizational readiness assessments, strategies for success in a FQHC Look-Alike application, as well as how we can help you to succeed in value based care, reach out to COPE Health Solutions at info@copehealthsolutions.com.