The Centers for Medicare & Medicaid Services’ (CMS) CY2025 Physician Fee Schedule (PFS) Proposed Rule, released in preview form on July 10, 2024, contains various provisions that will impact federally qualified health centers’ (FQHC) service offering and payment under Medicare. The rule contains provisions that will, if finalized, allow for various service expansions and enhancement in payments for FQHCs in Medicare, as well as building on the trend of greater recognition of technology-based services in Medicare. In particular, the proposals, if finalized, would allow CMS to carry out the following in CY2025:

1.  Broaden the capacity for FQHCs and other providers to use audio-only telehealth, rather than the audio-visual modality, where necessary to support patient care;

2.  Allow FQHCs to furnish and be paid for Medicare advanced primary care management (APCM) services—a more comprehensive approach to primary care targeted to individuals with greater clinical needs—and to receive additional payments for use of the APCM model;

3.  Require, for the first time, that FQHCs and rural health clinics (RHCs) bill Medicare for care management and care coordination using detailed codes; this change will allow FQHCs to be paid more for more resource-intensive care management services, and also to be paid add-on fees for add-on fees if time is spent on care management in a month in excess of the threshold requirement;

4.  Provide, for the first time, for separate initial payment to FQHCs for the administration of Medicare Part B-covered preventive vaccines including hepatitis B, pneumococcal, influenza, and COVID-19 vaccines (with payment for all of the latter three being later reconciled to the FQHCs’ documented costs on its cost report);

5.  Refine the payment methodology for FQHCs for intensive outpatient services (IOP), a behavioral health service added to the Medicare FQHC benefit effective Jan. 1, 2024, so that FQHCs could be paid at a higher rate for days of IOP services where more than four services are provided in a single day;

6.  Rebase the FQHC market basket inflationary index (CMS has done this only one time prior since the inflationary index was first introduced in 2017); and

7.  Postpone further (until Jan. 1, 2026) the implementation of a requirement that patients receiving telecommunications-based mental health visits in an FQHC have had an in-person mental health visit during the six months prior to the initiation of the telecommunications-based care.

Comments are due by Sept. 9. Click here to learn more and access the proposed rule.

The Pennsylvania Primary Care Career Center is seeking a Talent Acquisition Specialist to join their team and help Community Health Centers recruit primary care providers and other staff. If you know anyone who would be a great candidate for this position, please share the link to the job post and encourage them to apply online or send their resume and cover letter to Caitlin Wilkinson, Co-Director of the Pennsylvania Primary Care Career Center.

Legislation reining in prescription drug middlemen was signed by the Governor this week. House Bill 1993 deals with contracts between pharmacies and the 72 pharmacy benefit managers (PBM) operating in the state, transparency and accountability measures and pharmacies administering immunizations among other things. Through our aggressive advocacy, PACHC was able to have language added to help protect covered entities, including FQHCs, from pickpocketing by PBMs. The language in the bill in Chapter 6 states that, A PBM licensed by the department to conduct business in this Commonwealth may not, as part of a contract agreement issued or renewed following the effective date of this section with a pharmacist or pharmacy under this part reimburse a qualified health center or covered entity an amount lesser than similar entities not participating in the program under section 340(b) of the Public Health Service Act (58 Stat. 682, 42 U.S.C. § ). This language does not address the issue with contract pharmacies.

New investments will make it easier for social workers to practice across state lines, increase behavioral health access, and better facilitate telehealth services

Funding builds on HRSA’s work to support licensure compacts to improve access to primary care and psychology

The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced the first-ever Licensure Portability Grant Program investment in a multi-state social worker licensure compact. State licensure compacts allow states to come together on a common approach to licensing health care providers, allowing providers to practice across state lines without having to apply for a license in each state. Streamlining licensure while maintaining quality standards improves access to services both by better facilitating hiring and by easing pathways to utilizing telehealth. The announcement was made at HRSA’s National Telehealth Conference, the largest federal conference on telehealth issues.

“Social workers are essential to expanding access to behavioral health care services, a top priority of the Biden-Harris Administration,” said HHS Deputy Secretary Andrea Palm. “HRSA is leading the way in growing the behavioral health workforce both by training more providers and by breaking down barriers to allow the workforce to make mental health and substance use disorder services more accessible across the country.”

HRSA’s new $2.5 million investment in licensure compacts will support the work to launch a social worker compact as well as HRSA’s ongoing support for building and sustaining primary care, psychology, and podiatry compacts. HRSA identified behavioral health as a priority in its state licensure compact work. Since HRSA began investing in licensure compacts, the Interstate Medical Licensing Compact and the Psychology Interjurisdictional Compact (PSYPACT) have each grown to include 40 states, Washington, D.C., and one territory.

“Social workers are on the frontlines in responding to the Administration’s priorities, including meeting children’s mental health needs, responding to the opioid epidemic, and addressing maternal depression,” said HRSA Administrator Carole Johnson. “Today’s announcement is a critical step in helping social workers serve people in need, particularly in rural and underserved communities across the country.”

Today’s awards will support the Association of Social Work Boards, the Association of State and Provincial Psychology Boards, the Federation of State Medical Boards of the United States, and the Federation of Podiatric Medical Boards in working with state licensing boards to develop and implement state policies that reduce barriers to telehealth and allow for practice across state lines.

HRSA’s National Telehealth Conference brings public and private sector leaders together to discuss telehealth best practices to expand services in underserved and rural communities. This year, over 2,000 individuals registered to explore the future of telehealth including innovation, policy, and licensure issues.

To learn more about the Licensure Portability Grant Program, visit the Licensure Portability Grant Program Awardees webpage.

For more information on HRSA’s telehealth health work, visit the Office for the Advancement of Telehealth webpage.