Updates from your ACE team
School is back in session! Regardless of whether or not students are attending in person or virtually, it’s important to keep them healthy through the school year. Last month, we talked about the lack of vaccinations pediatric patients received since the beginning of the pandemic, why it happened and what it could mean for the school year. We’re here to help if you need assistance with staying ahead of what could be.

This month, we’re exploring dental practice expansion, Centers of Medicaid and Medicare's (CMS) new model, the Community Health Access and Rural Transformation (CHART) Model and what it means for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). We’re also discussing Health Resources and Administration's (HRSA) response to COVID-19 through the 340B Program and how it affects covered entities and updating you on HRSA audits of the 340B Program and telehealth. As telehealth continues to advance, we’ll keep you posted on our website and in future newsletters.

Our office will be closed Monday, September 7, 2020 for Labor Day. We will be back in the office on Tuesday, September 8, 2020. The ACE family wishes you and your family a very happy, safe and socially distanced Labor Day. 
Obtaining financial independence through dentistry

Practice expansion is one the keys that will work to help you achieve financial independence. This month, we’re exploring adding one or several dental services, which may include dentists and dental specialties to your facility.

Besides the fact that dentistry accompanies a full bill of health, dentistry can also help prevent childhood obesity, a huge issue that Americans are still battling.

The first step of expansion is analyzing your patient base to understand what their needs are and how you are currently meeting them. For example, if they require a dentist, are they seeing your dentist on-site, the one you have a contract with or another one? If they require dental surgery, are they seeing the oral surgeon, periodontist, endodontist, or other dental specialist that you have on-site, or a contract with or a different one?

If you don’t have a dentist or dental specialist on-site or a contract written with one, we can help! Our services include helping you find one, negotiating with them and writing a contract with them.
There is no better time to join the 340B Program
The U.S.' government agencies have been extremely proactive in their funding of and response to the pandemic through their programs. In its response to the pandemic, "HRSA" - the governing body of the 340B pharmacy program - "is allowing some covered entities, upon request and review, to enroll in the program" on a weekly basis in addition to the normal quarterly basis. If you've requested to be a part of the 340B Program, click here for the supplemental Medicaid Exclusion File (MEF), or the weekly updated list of covered entities that are now approved for the 340B Program. The list is updated every Friday.

"Manufacturers [that are] participating in Medicaid agree to provide outpatient drugs to covered entities at significantly reduced prices." The 340B Pharmacy Program allows covered entities to stretch limited resources to best serve their patient population, especially the underserved and uninsured. The program, if utilized properly, can pave the way toward financial independence.

Did 340B Pharmacy just get more complicated?
When was your last 340B HRSA audit? Are you prepared for a 340B pharmacy audit by HRSA? Since HRSA started completing 340B pharmacy audits, HRSA, dedicated to the integrity of the 340B pharmacy program, has increased the number of audits it performs while decreasing the covered entities' turnaround time. Maintaining a compliant 340B pharmacy program is not a simple task. Pharmacists must determine if the pharmacy is going to carve the Medicaid discount in or out and ensure they bill it correctly for the medication. We’ve mentioned in the past that States and pharmacies are eligible to take advantage of the Medicaid rebate; however, both parties are not able to collect the same rebate.

Now, manufacturers Merck, Sanofi, Lilly, Astra Zeneca and many more, are trying to weigh in on what contract pharmacies may receive the discounted prescriptions and which ones cannot, challenging HRSA's 2010 guidance. NACHC is concerned that, if other manufactures follow Merck and Sanofi’s lead, it could complicate the 340B pharmacy program for community health centers and, if the program is complicated for a health center, the other services that are supported by the 340B Program's savings will no longer be supported or available. It’s crucial, especially now, to have a 340B pharmacy program compliance toolkit for your 340B pharmacy program and HRSA and manufacture audits, to keep and maintain your 340B status.

Being prepared and compliant with a HRSA and manufacturer audit is crucial to maintaining a 340B pharmacy program. Working through an audit doesn’t have to be troublesome. ACE has Apexus certified experts that can help you breeze through an audit.

Our pharmacy experts assist by:
  • Ship to, bill to procedure
  • Patient eligibility verification
  • Prescriber eligibility verification
  • Comprehensive pharmacy services
  • Tracking system
  • Arrangement to prevent duplicate discounts
  • Audits - internal and external
  • Certification of contract pharmacy compliance
  • Response in the event of diversion or duplicate discounts
  • Re-certification process for covered entities

At the end of the audit, we offer you a detailed audit report that highlights compliance risks and includes a corrective action plan based on our findings.
Telehealth is here to stay!
Telehealth has made several advancements throughout the pandemic and has extended into pediatric care and pharmacy. Community health centers have substantially "expanded their use of telehealth over a very short period of time" to treat their patients throughout the pandemic.
Since our last update, President Trump signed an Executive Order on Improving Rural Health and Telehealth Access. This led CMS to propose expanding telehealth reimbursement after COVID-19! CMS’ current telehealth flexibilities for FQHC telehealth cannot stand, past the pandemic, without congressional action.
CMS has reached out to the public to understand what they would like to see permanently covered, especially in rural areas. According to the Executive Order, “rural healthcare providers need these types of flexibilities to provide continuous care to patients in their communities.” The purpose of the order is to “increase access to, improve the quality of, and improve the financial economics of rural healthcare, including increasing access to high-quality care through telehealth.”
The number of telehealth advancements are far from completion. Telehealth bills are starting to add up for the government to consider. These bills include the ones CMS has put forth.
From the Hill and other useful info
The House and Senate were unable to reach an agreement for the latest emergency funding, the Health, Economic Assistance, Liability Protections and Schools (HEALS) Act. The HEALS Act provided "an additional $7.6 billion for [FQHCs] ongoing COVID-19 related needs." The funding was intended to help clinics make up for revenue losses, along with extensions to the Paycheck Protection Program (PPP), funding infrastructure for scaling up telehealth services and supporting critical workforce programs.

Congress has still not secured 5 years of long-term funding for FQHCs, which is necessary for post pandemic health care. The funding is set to expire on November 30, 2020. Regardless of where you are geographically, ask your local representatives to extend community health centers' funding.

Speaking of funding, here's some of the latest funding opportunities:

CMS continues its innovation streak with the (CHART) Model, or the “Model.” The model works to assist the approximate 57 million Americans – including Medicare and Medicaid beneficiaries – that face healthcare challenges, such as limited transportation services, shortages of health care services, an inability to fully benefit from technological and care-delivery innovations. These challenges frequently cause these patients to face worse health outcomes and higher rates of preventable diseases than patients living in urban areas.

The Model has three goals:
  • Increase financial stability for rural providers through the new ways providers are reimbursed that provide up-front investments and predictable, capitated payments that pay for quality and patient outcomes
  • Remove regulatory burden by providing waivers that increase operational and regulatory flexibility for rural providers.
  • Enhance beneficiaries’ access to health care services by ensuring rural providers remain financially sustainable for the future and can offer additional services, such as those that address social determinants of health, including food and housing.

The CHART Model will test if upfront investments, predictable capitated payments and operational and regulatory flexibilities will enable rural health care providers to improve access to high quality care while reducing health care costs.

For more information on the model, CMS’ plans and how you meet the requirements for funding click HERE.

On August 20, 2020, the U.S. Department of Health and Human Services (HHS), through HRSA, awarded more than $35 million to FQHCs and RHCs. The funds are to support and increase access to high quality care in rural communities. The awards reflect investments in telehealth, workforce training, health research, technical assistance for vulnerable rural hospitals and HIV care and treatment.

HRSA continues to track COVID-19. Click HERE for the latest news.

NACHC released new data concerning health center's response to COVID-19. Since April 3, 2020, over 2.8 million health center patients have been tested for COVID-19. Since NACHC released the last version of their stats, 96 percent of FQHCs have the ability to test for COVID-19 and 80 percent have walk-up or drive-up testing. This week, 96 percent of health centers conducted visits virtually and health center visits remain below normal at 79 percent.

NACHC continues to track COVID-19. Click HERE for the latest news.