CMS Issues Several Documents of Importance to Health Centers

Last week CMS published two documents last week which will strengthen health centers’ and PCAs’ ability to protect their payment rights under Medicaid managed care. They are:

We will be providing detailed information on both of these documents in the near future. In the short term, here is a listing of key policies around PPS reimbursement that were announced in these documents:

  • Starting in July 2017, States may “delegate wrap” to MCOs only for those FQHCs that have agreed to this approach.
  • Starting in July 2017, every Medicaid and CHIP MCO will be required to contract with at least one FQHC in each service area.
  • Incentive payments made by Medicaid MCOs may not be counted against PPS payment.
  • Value-based payment (VBP) arrangements must adhere to the statutory requirements for PPS.

As we noted, more detailed information will be coming soon. In the meantime, if you have any questions please contact Colleen Meiman or Susan Sumrell.

ICHIA: The Legal Immigrant Children’s Health Improvement Act

By: Esther Grambs

In 1996, the Personal Responsibility and Work Opportunity Act signed by President Bill Clinton barred legally residing immigrants from accessing Medicaid and CHIP benefits during their first five years of residency.  The re-extension of these benefits was introduced by Senators Hillary Clinton and Olympia Snowe in 2007 as the Legal Immigrant Children’s Health Improvement Act.  It was adopted as part of the Medicaid and Chip Reauthorization Act of 2009 as an optional expansion of the Medicaid program that allows states to extend Medicaid and CHIP coverage to documented immigrant children and pregnant women who meet other Medicaid and CHIP requirements.[1]  At this time, 31 states have adopted the ICHIA expansion[2], the most recent being Florida and Utah in March 2016. Insurance rates for immigrant children in those states was 62%, compared with just 21% in states that did not adopt the expansion.[3]

Latino children have disproportionately high rates of uninsurance due to the low-income and mixed immigration status of many Latino families, especially ones where children may be citizens or lawfully residing but parents may be undocumented.  People without insurance are more likely to utilize emergency room services, but families with undocumented members are less likely to use emergency room services and more likely to forgo medical treatment altogether.  The Medicaid and CHIP programs provide coverage of comprehensive preventive care, meaning better health outcomes for children, pregnant women, and infants.[4]



[1] Youdelman, Mara. “Q & A: The Legal Immigrant Children’s Health Improvement Act.” National Health Law Program (blog). Entry posted June 1, 2013. Accessed April 15, 2016.

[2] Georgetown University Health Policy Institute. “CHIP and Health Coverage for Lawfully Residing Children.” Georgetown University Health Policy Institute Center for Families and Children. Last modified March 15, 2106. Accessed April 15, 2016.

[3] Schwartz, Sonya. “Research Shows that Utah and Florida’s “ICHIA Option” Will Improve Access to Health Coverage and Services for Lawfully Residing Immigrant Children.” A Children’s Health Policy Blog. Entry posted March 14, 2016. Accessed April 15, 2016.

[4] Ibid.

CMS Announces Provider Call on Revalidation

We wanted to make sure you were aware of this provider call from CMS on Medicare revalidation.  See the announcement below for information on the call and registration information.

Provider Enrollment Revalidation Call — Register Now
Tuesday, March 1 from 2 to 3:15 pm ET

To Register: Visit MLN Connects Event Registration. Space may be limited, register early.
What’s ahead for your next Medicare enrollment revalidation? Learn what you need to do and about the new resources available to help you stay on top of the process every step of the way. Join CMS experts as they discuss the timing, improvements, and updates for the second round of revalidations required by the Affordable Care Act and 42 CFR §424.515. A question and answer session will follow the presentation.

Target Audience: All Medicare fee-for service providers and suppliers. Note: providers enrolled solely to order and refer items or services to Medicare beneficiaries and practitioners who have opted out of the Medicare program are not required to revalidate.
Continuing education credit may be awarded for participation in certain MLN Connects Calls. Visit the Continuing Education Credit Information webpage to learn more

Important Webinar for Providers Who Prescribe to Patients 65 and Older


CMS is holding a webinar on the requirement for all Medicare Part D prescirbers to be enrolled in Medicare by JUne 1, 2016.  Please see the message from CMS below.

Previously, the Centers for Medicare & Medicaid Services announced that prescribers of Part D drugs need to be enrolled in Medicare by June 1, 2016. Patients 65 years of age and older are likely to have a Medicare Prescription Drug Plan (Part D) – if you prescribe to patients that age, you should enroll.

PECOS: Step-by-Step Online Enrollment for Part D Prescribers Webinar
Thursday, February 18, 2016 from 1-2pm EST
The webinar will cover background on the requirement, how to enroll online (walking through the process step-by-step), opting out, additional resources, and a question and answer period.

For more information, visit our at Part D Prescriber Enrollment website or contact your local MAC.

Emerging Issues for Health Centers in State Telehealth Policy

By Heidi Emerson

Although telehealth is not a new concept, new technologies, greater comfort with technology, and changing payment models are driving increasing use by patients and providers. As a result, there has been new activity and interest in supporting the use of telehealth to expand access and improve care at health centers:

  • In a rural county in Georgia, Mercer University School of Medicine has coordinated a special program which was launched in the summer of 2015 with funding by the Governor’s budget.[1] In a county with no doctors or hospital, Community Health Care Systems, a health center in Sparta, has been using the program to conduct electronic home visits.
  • Ravenswood Family Dentistry, a health center in San Mateo, California, has been using teledentistry to provide dental exams to children at a Head Start center in an area where dental care is limited, or dentists do not accept new Denti-Cal patients.[2]
  • In Mississippi, a new rule that took effect on Dec. 1, 2015 has added language to allow FQHCs or look-alikes to be reimbursed an additional fee as an originating site.[3]  (Mississippi Regulations, 10/27/15)

These are only some examples of how state programs and policies facilitate the use of technology to deliver care at health centers. According to a legislative scan by the Center for Connected Health Policy (CCHP), over 200 pieces of legislation related to telehealth were introduced in the 2015 state legislative sessions.  In addition to legislation around reimbursement and payment, some of the other policies and programs that are being considered by states include the Interstate Medical Licensure Compact[4] passed by 12 states, and the Nurse Licensure Compact which preceded the physician compact by 15 years, with 25 states participating.[5] The Nurse Licensure Compact would allow nurses to practice in both their home state and other compact states with a multistate license.  The Medical Licensure Compact would streamline or expedite the licensing process for physicians practicing in multiple states.

Expansion of broadband networks to facilitate connections for telehealth are also being considered by states such as West Virginia.  Funding for the expansion of broadband access is also available as part of the Federal Communications Commission’s National Broadband Plan through the FCC’s Rural Health Care Program, and its Healthcare Connect Fund, created in 2012. [6]

According to a 2015 report released by the Robert Graham Center and the American Academy of Family Physicians (AAFP), reimbursement continues to be a major barrier for physicians in utilizing telehealth in their practices.[7]  In their survey of 1,557 physicians, among users of telehealth, the most common use was for referrals to specialists (68%) and mental health providers (28%).  For health centers, other challenges include the complexity of billing and reimbursement rules, shortages of providers, interoperability of data systems, and coding of telehealth claims and encounters, according to a report from CCHP that examined telehealth programs at 3 federally qualified health centers and 2 rural health centers in California.[8]

The National Conference of State Legislatures (NCSL) released a report that reviews telehealth policy trends and focuses on three issues: coverage and reimbursement, licensure, and safety and security.[9] Furthermore, the report provides a policy checklist for legislators on these three key issues, and suggests that other ways that states can support telehealth include state reforms that transform care delivery through state plan amendments, waivers and grants. Similar to other reports, other policy issues to consider are liability coverage, scope of practice, credentialing and privileging, prescribing and informed consent.

As we start 2016, it is likely that telehealth and telemedicine policy will be topics under consideration by both states and Congress. It is worth watching policies that will ease restrictions, promote reimbursement, and will allow the use of technology to expand access to both primary and specialty care. The integration of telehealth into practice can improve quality of care for the chronic and complex conditions of the vulnerable populations that health centers serve.

For other resources on state telehealth policies that impact health centers, please see NACHC’s 2013 report, and 2015 issue brief.





[4] For more information:;

[5] For more information:

[6] For more information, see also:

[7] Family Physicians and Telehealth: Findings from a National Survey, Robert Graham Center, October 30, 2015. Accessed at:

[8] Community Health Centers and Telehealth: A Cost Analysis Report and Recommendations. Center for Connected Health Policy, July 2015.

[9] Telehealth Policy Trends and Considerations, National Conference of State Legislatures, December 2015. Accessed at: