The Federally Qualified Health Center LookAlike Program: Past, Present, and Future

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The Federally Qualified Health Center Look-Alike
Program Past, Present, and Future
Health Resources and Services Administration2008
Primary Health Care All-Grantee Meeting

• Tonya Bowers, Interim Director
• Twyla Adams, Branch Chief
• U.S. Department of Health and Human Services
• Health Resources and Services Administration
• Bureau of Primary Health Care

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Workshop Objectives

• This workshop will
• Cover the basics of the FQHC Look-Alike Program.
• Exam the recent trends under the FQHC Look-Alike
  Program.
• Present the challenges and opportunities for the
  FQHC Look-Alike Program.

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Basics of the FQHC Look-Alike Program
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Background

• Medicare and Medicaid statutes define the
  provider type Federally Qualified Health Center
  (FQHC)
• Social Security Act 1861(aa)(4) and
  1905(l)(2)(B) respectively.

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Definition of an FQHC

• An entity that receives a grant under section 330
  of the Public Health Service Act (PHSA) Health
  Center Program
• Community Health Center Program Section 330(e).
• Migrant Health Center Program Section 330(g).
• Health Care for the Homeless Program Section
  330(h).
• Public Housing Primary Care Program Section
  330(i).
• An entity that is determined by DHHS to meet
  requirements to receive funding without actually
  receiving a grant (i.e., requirements for an
  FQHC Look-Alike entity are found in PINs
  2003-21 2005-17).

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FQHC Look-Alike Eligibility Requirements

• Must be a private, charitable, tax-exempt
  nonprofit organization OR public entity (direct
  or co-applicant arrangement).
• Must serve a medically underserved area (MUA) or
  medically underserved population (MUP) designated
  by DHHS.
• Must not be owned, controlled or operated by
  another entity.
• Must be operational and providing primary care
  services at the time of application submission.

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Benefits of FQHC Look-Alike Status

• Eligible for
• Enhanced reimbursement under Prospective Payment
  System (PPS) or other state-approved alternative
  payment methodology for services provided under
  Medicaid.
• Cost-based reimbursement for services provided
  under Medicare.
• Have access to favorable drug pricing under
  Section 340B of the PHSA.
• Have the right to have outstationed Medicaid
  eligibility workers.

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Benefits of FQHC Look-Alike Status

• Safe harbor under the Federal anti-kickback
  statute for waiver of co-payments to the extent a
  patient is below 200 of Federal income poverty
  guidelines.
• Reimbursement by Medicare for "first dollar" of
  services rendered to beneficiaries, i.e.,
  deductible is waived.
• Access to providers through the National Health
  Service Corps if the health center's service area
  is designated a Health Professional Shortage Area
  (HPSA).
• Access to the Federal Vaccine For Children
  program and eligibility to participate in the
  Pfizer Sharing the Care Program.

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FQHC Look-Alike Program Administration

• The FQHC Look-Alike Program is operated under an
  intra-agency agreement between HRSA and CMS.
• HRSA is responsible for
• Assuring compliance with requirements under
  section 330 of the PHSA.
• Making a recommendation to CMS for designation as
  an FQHC Look-Alike.
• CMS has final authority to designate applicants
  as an FQHC Look-Alike.

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FQHC Look-Alike Program Administration

• HRSA staff are responsible for
• Developing the application guidance.
• Providing technical assistance to applicants and
  existing FQHC Look-Alikes.
• Reviewing applications.
• Coordinating site visits.
• Monitoring continued compliance.

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Recent Trends under the FQHC Look-Alike Program
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FQHC Look-Alike Project Officers

• Twyla Adams (301-594-4439)
• Branch Chief
• Cristina Petruccelli (301-594-4118)
• CT, ME, NH, RI, VT, AL, FL, GA, KY, MS, NC, SC,
  TN
• Cicely Nelson (301-594-4496)
• AR, LA, NM, OK, TX
• Blanca Fuertes (301-443-0612) and Michelle Parker
  (301-594-4285)
• OH, MI, WI, MN, IL, IN, MO, IA, NE, KS
• Valerie Bowers (301-443-7364)
• NY, NJ, MD, WV, VA, SD, ND, CO, MT, UT, ID, WA,
  OR, WY, PR, DE, PA, DC, AR
• Bette Darling (301-594-4342)
• CA, NV, AZ, HI

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FQHC Look-Alike Program Growth 1991-2007
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Number of Applications and New Designations
2004-2007
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Success Rates for NAP Funding2002-2007

• Of the FQHC Look-Alikes that applied for NAP new
  start funding
• FY 2002 43 (24/56) were successful.
• FY 2003 33 (17/51) were successful.
• FY 2004 7 (4/58) were successful.
• FY 2005 33 (12/36) were successful.
• FY 2006 59 (22/37) were successful.
• FY 2007 48 (23/48) were successful.

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Success Rates for NAP Funding2002-2007

• Of the organizations that received NAP new start
  grants
• FY 2002 27 (24/88) were FQHC Look-Alikes.
• FY 2003 32 (17/53) were FQHC Look-Alikes.
• FY 2004 15 (4/27) were FQHC Look-Alikes.
• FY 2005 28 (12/45) were FQHC Look-Alikes.
• FY 2006 40 (22/55) were FQHC Look-Alikes.
• FY 2007 47 (23/49) were FQHC Look-Alikes.

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Challenges and Opportunities for the FQHC
Look-Alike Program
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Challenges

• Challenge 1 Reviewing initial submissions of
  FQHC Look-Alike new designation applications in
  which 90-95 are non-compliant.
• Challenge 2 Having partners who are not
  knowledgeable about the FQHC Look-Alike Program.
• Challenge 3 Streamlining data collection for
  increased program analysis.

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OpportunitiesAssure Compliance

• Revise the FQHC Look-Alike application guidance.
• The goals of the revised guidance are to
• Enhance clarity in conveying HRSAs expectations
  to applicants.
• Better align FQHC Look-Alike application
  requirements to those in the section 330 grant
  program.

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OpportunitiesAssure Compliance

• Proposed revisions to the existing application
  guidance include
• Creation of designation periods up to 5 years.
• Adoption of application forms used in the section
  330 grant applications.
• Submission of 5-year health care and business
  plans.
• Allowance of governance waivers for organizations
  that serve special populations as defined in
  section 330 of the PHSA.

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OpportunitiesAssure Compliance

• Status of revised application guidance
• Draft guidance was released for a 60-day public
  comment in the fall of 2007.
• Draft guidance will be released for a second
  60-day public comment in the summer of 2008 as a
  result of the comments received and resulting
  changes.
• HRSA projects releasing the revised application
  guidance in final in the fall of 2008.

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OpportunitiesAssure Compliance

• Conduct compliance site visits to verify
  compliance with requirements under section 330 of
  the PHSA.
• Description of compliance site visits
• 10 pre-designation and 10 post-designation
  compliance site visits will be conducted in FY
  2008.
• An organization may receive a compliance site
  visit if its paper application for new
  designation or recertification is approvable.
• To ensure diversity, selection factors will
  include geographic region, urban/rural,
  private/public, and single site/multiple sites.
• If areas of non-compliance are identified during
  the site visit, HRSA will provide the
  organization with technical assistance in order
  to come into compliance.

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OpportunitiesAssure Compliance

• Status of the compliance site visits
• HRSA will disseminate a Program Assistance Letter
  that provides more specific information about the
  compliance site visits in the summer of 2008.
• HRSA will implement the compliance site visits in
  the summer of 2008.

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OpportunitiesStrengthen Partnerships

• Develop and strengthen relationships with
  partners to increase their knowledge and
  understanding of the FQHC Look-Alike Program by
• Convening brown bag sessions for HRSA staff.
• Defining roles for partners.
• Developing additional educational materials.
• Convening national conference calls.

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OpportunitiesStreamline Data Collection

• HRSA anticipates integrating the FQHC Look-Alike
  Program into the HRSA-wide EHB System in 2009.
• At that time, new applicants and existing FQHC
  Look-Alikes will be able to submit applications
  electronically.
• It will facilitate data extraction in order to
  analyze data trends.

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• Questions?

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Contact Information

• Tonya Bowers
• Interim Director
• U.S. Department of Health and Human Services
• Health Resources and Services Administration
• Bureau of Primary Health Care
• 5600 Fishers Lane Room 17C-26
• Rockville, MD 20857
• Telephone [phone]
• Fax [phone]
• E-mail Tonya.Bowers_at_hrsa.hhs.gov

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Contact Information

• Twyla Adams
• Branch Chief
• U.S. Department of Health and Human Services
• Health Resources and Services Administration
• Bureau of Primary Health Care
• 5600 Fishers Lane Room 17C-26
• Rockville, MD 20857
• Telephone [phone]
• Fax [phone]
• E-mail Twyla.Adams_at_hrsa.hhs.gov