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Securing the safety net: Current compliance issues in Federally Qualified Health Centers

Todd A. Nova (tnova@hallrender.com) and T. James Junger (jjunger@hallrender.com) are Attorneys in the Milwaukee office of Hall Render Killian Heath & Lyman. Lauren M. Harris (lauren.harris@leehealth.org) is an Associate Attorney at Lee Health in Fort Myers, FL.

Federally Qualified Health Centers (FQHC) are a crucial component of the nation’s healthcare safety net, providing structured access to primary and specialty care in underserved communities. Operating an FQHC is a uniquely challenging endeavor. FQHCs are eligible for numerous federal and state benefits, such as grant funding under Section 330 of the Public Health Service Act, discounted drug pricing under the 340B Drug Discount Program (340B Program), enhanced Medicare payment under the Centers for Medicare & Medicaid Services (CMS) FQHC Prospective Payment System, cost-based reimbursement under the Medicaid program, protections from Anti-Kickback Statute restrictions, and access to various federal and state practitioner recruitment programs. Of course, in exchange for access to these benefits, an FQHC agrees to comply with a wide array of statutory and regulatory obligations.

This article describes contemporary hot topics in FQHC compliance with the goal of helping FQHC executives and compliance professionals update their compliance work plans to identify potential trouble spots before they develop into significant compliance concerns. Each section describes practical steps that a compliance professional can take to address these concerns.

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