Eastern Shore Rural Health System, Inc. (ESRHS) submits these comments on a matter of great consequence to community health centers. The timely processing of change-in-scope requests within 90 days is critical to Federally Qualified Health Centers (FQHCs) like ours. Two items relevant to this request are cited below.

• 12VAC30-80-25:B.1-Reimbursement for FQHCs and rural health clinics (RHCs): Beginning Oct. 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 Jan. 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.

Beginning in May 2020 ESRHS has focused on adding more locations to increase access to care in our region. We opened Eastville Community Health Center, a new larger state-of-the-art facility that brought digital X-ray and behavioral health care to Northampton County, these services were previously unavailable. Additionally, new oral care access points for Medicaid beneficiaries were opened at our Eastville center and Nandua Middle and Kiptopeke Elementary Schools. In 2023 we added an urgent care site that allows Medicaid beneficiaries to receive care for issues that might have otherwise landed them in the ER. During this time, we also added behavioral health care services to Eastville, Onley and Atlantic Community Health Centers. Uncompensated care continues to grow due to the lack of ability to submit a change in scope. Our calculations show that over the last three fiscal years ESRHS has provided $1,245,710 in uncompensated care while these additional services resulted in 84,000+ patient visits.

After more than 20 years of waiting and in compliance with item 288 WWWW, ESRHS, a Virginia FQHC, 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.

Respectfully, Jeannette Edwards CEO