Health Resources and Services Administration 2008 Primary Health Care All-Grantee Meeting The Federally Qualified Health Center Look-Alike Program: Past, Present, and Future 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 June 23, 2008

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. June 23, 2008

Basics of the FQHC Look-Alike Program June 23, 2008

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. June 23, 2008

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). June 23, 2008

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. June 23, 2008

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. June 23, 2008

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. June 23, 2008

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. June 23, 2008

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. June 23, 2008

Recent Trends under the FQHC Look-Alike Program June 23, 2008

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 June 23, 2008

FQHC Look-Alike Program Growth 1991-2007 Slides shows a growth trend. Data is captured for any organization that was active during any part of the year. (Val) Could offer explanation that the numbers are very similar and there isn’t much growth between 2004-2007 because of LAL’s being de-designated due to becoming a 330 grantees June 23, 2008

Number of Applications and New Designations 2004-2007 Applications received in a given year include a number of items: The number of applications received, reviewed and designated The number of designated and de-designated (funded) on the same year The number of applications reviewed and denied The number of applications reviewed but unresolved on the year received. June 23, 2008

June 23, 2008

Success Rates for NAP Funding 2002-2007 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. Twyla: might want to consider taking the 2002 data – most of the presentation has data for 2003 – 2007. June 23, 2008

Success Rates for NAP Funding 2002-2007 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. Again, this shows that of the universe of NAP new start awardees, a significant percentage were LALs, therefore the LAL program has been an important route health centers have used to eventually achieve grantee status June 23, 2008

Challenges and Opportunities for the FQHC Look-Alike Program June 23, 2008

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. June 23, 2008

Opportunities: Assure Compliance Revise the FQHC Look-Alike application guidance. The goals of the revised guidance are to: Enhance clarity in conveying HRSA’s expectations to applicants. Better align FQHC Look-Alike application requirements to those in the section 330 grant program. June 23, 2008

Opportunities: Assure 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. June 23, 2008

Opportunities: Assure 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. June 23, 2008

Opportunities: Assure 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. June 23, 2008

Opportunities: Assure 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. June 23, 2008

Opportunities: Strengthen 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. June 23, 2008

Opportunities: Streamline 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. June 23, 2008

Questions? June 23, 2008

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: 301.594.4300 Fax: 301.594-4984 E-mail: Tonya.Bowers@hrsa.hhs.gov June 23, 2008

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: 301.594.4300 Fax: 301.480.7225 E-mail: Twyla.Adams@hrsa.hhs.gov June 23, 2008