CCHP Releases Factsheet Based on Policies in New FQHC Category of Policy Finder


October 25, 2022

Last week’s latest update to CCHP’s Telehealth Policy Finder included a brand-new feature: a category specifically for federally qualified health centers' (FQHC) Medicaid fee-for-service policies. Funded by the National Association of Community Health Centers (NACHC) through funding from the Health Resources and Services Administration (HRSA), the new section includes the many unique rules that apply to FQHCs that sometimes effect their ability to utilize telehealth.

CCHP is now making a factsheet available summarizing the findings from our new FQHC section. CCHP searched statute, state Medicaid manuals, administrative code and fee for service polices between July and early September 2022, for relevant policies. In some categories, the factsheet reports a certain number of states that are reimbursing for a specific modality or the prospective payment system (PPS) rate. Note that CCHP only counts states as providing reimbursement if official and explicit Medicaid documentation was found confirming they are reimbursing FQHCs specifically for a certain modality. A broad statement that all providers are reimbursed or any originating site is eligible without an explicit reference to FQHCs was insufficient. Additionally, a state Medicaid program was counted as reimbursing FQHCs even if they do so in a very limited way, such as only for mental health.

Definition of Encounter/Visit: The majority of Medicaid programs do provide a definition for a FQHC ‘encounter’ or ‘visit’ that stipulates that it is a face-to-face interaction. This does not necessarily preclude use of telehealth as live video can also be considered ‘face-to-face’.
Same-Day Visits: CCHP examined each state Medicaid program’s policy on ‘same day encounters/visits’. Many states have limitations around FQHCs claiming more than one encounter in a single day for a single patient. This is thought to be a limitation applicable to telehealth because it is common for a patient to visit a FQHC for a primary care visit, and upon examination require a specialty service (such as mental health). CCHP observed that most state Medicaid programs do indeed have limitations around same day encounters, particularly if the services occur at the same location and are both considered the same type of encounter (for example, a medical encounter). However, there are often allowances for multiple encounters if the service is considered a different type of encounter, for example a mental health encounter.
FQHCs as Originating Sites: 36 states and DC explicitly allow FQHCs to serve as originating sites for telehealth-delivered services. If a state does reimburse a facility fee, it is common for FQHCs to be eligible to collect the fee, however not every state Medicaid program reimburses the facility fee.
FQHCs as Distant Site: 34 states and DC explicitly allow FQHCs to be distant site providers. This was often stated in Medicaid manuals or regulations as a clarification so that there could be no confusion about their eligibility for reimbursement.
FQHCs Collecting the Prospective Payment System (PPS) Rate: In some cases, policy addressed whether or not FQHCs would be eligible for the prospective payment system (PPS) rate. Twenty state Medicaid programs and DC explicitly clarify that FQHCs are eligible for the PPS rate when serving as distant site providers.
Store and Forward Reimbursement: The vast majority of states did not specify or excluded store-and-forward from an eligible service FQHCs could be reimbursed for. Only 4 state Medicaid programs explicitly reimburse FQHCs for store-and-forward.
Audio-Only Reimbursement: 9 state Medicaid programs explicitly allow reimbursement for audio-only services to FQHCs. In some cases, services are only reimbursed through communication technology-based services (CTBS) codes, or have other restrictions (such as limitations around the service type) limiting its use.
Remote Patient Monitoring Reimbursement: While most states did not address whether or not FQHCs would be eligible for remote patient monitoring, in a few instances CCHP noted states that allowed them to be reimbursed through CTBS codes, although separate from their ‘core services’ or encounter rate.
Services Outside the Four Walls: FQHCs have sometimes had to adhere to rules restricting services from being rendered outside of the four walls of their facility. This can pose a problem for telehealth encounters when the patient may be at home and connecting to a FQHC provider. CCHP found that Medicaid policies did not always address this situation explicitly, and the policies that were found often did not address a telehealth situation explicitly leaving it ambiguous whether this model of care is allowed.
FQHC Limitations on Establishing a Patient Provider Relationship: This was examined as a topic area for each state, but only California was found to have such requirements.
For more detailed explanations, examples of each topic area above, and a chart reporting whether each state reimburses FQHCs for the specific modalities or PPS rate, see the Telehealth Policies and FQHCs Factsheet.

For each state’s specific FQHC policies,
along with links to source materials,
see the new FQHC section of CCHP’s Policy Finder.

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