After more than 20 years of waiting and in compliance with item 288 WWWW, Southern Dominion Health System, respectfully requests the implementation of this policy, along with the new PPS rate, effective January 1, 2025. We also request reimbursement for any unreimbursed costs incurred prior to the submission in accordance with applicable federal law.

Community Health Centers are a lifeline to so many underserved patients in Virginia. Health systems such as ours and many more across the state truly address all patient needs, often going outside the 4 walls of the exam room to help patients with any barriers to care that they may face. This includes transportation, language needs, medication assistance, behavioral health needs and so much more. We ask that reimbursement rates be evaluated annually in a manner that will account for time and complexity of services rendered.

In keeping with the applicable legislation, we would like to respectfully request that any timelines associated with the Change in Scope filing, determination, or appeals process are achievable and timely.

• 12VAC30-80-25:B.1-Reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs): Beginning October 1, 2001, and for each fiscal year thereafter, each FQHC/RHC shall be entitled to the payment amount (on a per-visit basis) to which the center or clinic was entitled under BIPA of 2000 in the previous fiscal year, adjusted by the percentage change in the Medicare Economic Index (MEI) for primary care services, and adjusted to take into account any increase or decrease in the scope of services furnished by the FQHC/RHC during its fiscal year.
   
• Budget Bill - Item 288 WWWW: DMAS shall implement a process no later than January 1, 2025, for FQHCs to notify the department of any changes in the scope of services offered by an FQHC, pursuant to Section 1902(bb)(3) of 42 U.S.C. 1396a. The department is authorized to reimburse FQHCs for unreimbursed costs, as allowed by the applicable federal law, prior to an initial request for a change in scope under the new process.

Respectfully,

Albert Brogan

Chief Financial Officer

Community Health Center of the New River Valey