Behavioral healthcare providers have two key issues at hand: meeting the requirements of healthcare reform and addressing the funding shortages which have all but put them out of business. In a way, these two issues can be resolved together, and last week, the National Council for Community Behavioral Healthcare told over 400 providers how during its free webinar, “Are You Ready to Become a Federally Qualified Health Center (FQHC)?”
Led by Pamela J. Byrnes, PhD, Director of Health Center Growth and Development at the National Association of Community Health Centers, Inc. (NACHC), the webinar covered requirements for becoming a FQHC, which is a comprehensive health provider that receives both grants and enhanced Medicaid and Medicare reimbursements. With integration of primary and behavioral health services a requirement of healthcare reform, a provider’s pursuit of FQHC status could be the solution it needs to stay afloat financially and keep up with industry changes.
Criteria for FQHC status
Last week’s announcement of $250 million in available grant funding for New Access Points by the U.S. Department of Health and Human Services (HSS) presents a perfect opportunity for behavioral health providers to start looking toward the future as a FQHC. Whether an organization already satisfies many of the requirements or simply has a solid plan to do so, a provider at any stage that meets or plans to meet basic criteria can apply for FQHC status with the Health Resources and Services Administration (HRSA).
“The more compliant and operational you are, the likelier you are to get funded,” Byrnes said. “But paper starts do get funded.”
According to Byrnes, the basic criteria for meeting FQHC status are:
• Be a nonprofit or public entity and a Medicaid/Medicare provider;
• Operate as a Community Health Center serving medically underserved areas or populations as outlined by the federal government, OR operate under The Health Center Program as a Migrant Health Center, Health Care for the Homeless Program, or Public Housing Primary Care Program;
• Adhere to Board of Directors governance requirements;
• Provide primary, preventive, supplemental, and case management services; and
• Adhere to access, staffing, and organizational management requirements.
Providers are also able to achieve FQHC “lookalike” status, which means that they aren’t eligible or funding isn’t available for grants under The Health Center Program, but they have met basic criteria to receive the enhanced Medicaid and Medicare reimbursements.
As the NACHC’s Director of Health Center Growth and Development, Byrnes helps providers through the application and readiness process, as well as provides training and technical assistance to current FQHCs. It’s only natural, then, that she’s picked up a few tricks along the way, and she shared them with webinar participants.
Understanding medically underserved designations. Byrnes cleared up any assumptions for her behavioral health-centric audience from the get-go: persons with mental illness are not considered medically underserved populations. In fact, no disease is considered a population; rather, these designations are reserved for income status or ethnicities, among others.
Similarly, Byrnes pointed out that providers may be closer to medically underserved areas than they may think. For instance, she said that though a provider may not reside within an underserved area, they can still be considered as long as they can prove their location is accessible to the underserved area. To find medically underserved areas in your state or county, use the HRSA’s Find Shortage Areas online tool .
Putting your board together. FQHCs must follow strict guidelines for the formation of a governing board of directors in order to maintain their status and integrity. For instance, Byrnes said that of the nine to 25 board members required, a majority must be consumers of the FQHC’s services.
“This works because the people who receive the care drive the bus,” she said. In addition, she pointed out that no more than half of the non-consumer members may make more than 10 percent of their income in the healthcare industry.
Providing primary care. According to Byrnes, FQHCs are required to provide basic primary and preventive services, including oral health, as well as “supplemental services,” which include mental health and substance abuse services. In addition, FQHCs must provide case management services to consumers in order to link them with needed community resources.
This can pose a significant challenge for behavioral health providers who often have little experience integrating with other services. Byrnes said that contracting with other providers could be a good alternative, although having “that provider in the health center for some amount of time per week” is essential.
In addition, Byrnes noted that “[focusing] in on the core primary care services” is a good start for providers who lack comprehensive offerings, and told participants to keep in mind that there are different required services for different populations.
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