Since the 2016 presidential election, the US healthcare industry has been bracing for some significant changes. The Affordable Care Act (ACA), while certainly not perfect, has helped move the US toward universal health coverage. As part of the Obama Administration's healthcare strategy, Community Health Center (CHC) funding was increased and moved under the ACA. This year’s initial ACA replacement proposal, the American Health Care Act (AHCA), was unable to gain traction in Congress and was withdrawn. While the ACA is still the law of the land, it clearly has a target painted on it. Amidst all of this uncertainty, how can health centers plan and prepare for continued financial stability?
The 340B Program will be accepting Health Center Program grantee registrations beyond the standard two-week registration period (April 1-15). Health centers will be able to register a site that has been verified as implemented and the site status is reflected as “active” in EHBs Form 5B through June 9, after which the system will close to prepare for the July 1 start. A similar quarterly registration timeframe will be employed each quarter.
In a move that should surprise no one, the Office of Information and Regulatory Affairs (OIRA) announced that the 340B Program Omnibus Guidelines, aka the 340B Mega Guidance, was withdrawn on January 30th. The proposed rule, which was released in draft form in August 2015, was widely expected to be finalized last December. As a unit of OMB, OIRA speaks directly for President Trump's executive branch.
I don’t care who you are – You should be scared of Zika. And, by scared, I don’t mean that you should panic. That doesn’t help anyone. But this virus needs to be taken seriously - And I'm not alone here, even public health experts are sounding the alarm. There is still so much that is unknown about it’s transmission and the possible long-term effects for those infected.
Here at FQHC Associates, we get many inquiries about starting or becoming a Federally Qualified Health Center (FQHC). We hear from a wide range of individuals and organizations, but most inquiries come from existing health care organizations who see the benefits in transitioning to an FQHC model of care, both to the community-at-large and to the organization itself.
The 340B Program has become an important source of revenue for many Federally Qualified Health Centers. Many fear that without 340B, their programs will not survive. With a draft Mega Guidance under consideration by HRSA and new CMS rules governing Medicaid reimbursement, 340B is going to change. The extent to which this will affect FQHCs is currently a matter of speculation. Meanwhile, in order to understand where this crucial program is likely headed, it is important to know where we are now, and how we got here.
Besides not dying young, one of the advantages of being around for a long time is that you gain perspective.