(Recorded Training) Medicare and Medicaid Behavioral Health in the FQHC: New Opportunities

Duration: 3.5 hours
Recorded on: 9/21/2022

In both the Medicare program and Medicaid programs, recent policy changes have resulted in improved access to behavioral health services, including in federally qualified health centers (FQHCs). In this half-day training, FTLF attorneys Susannah Vance Gopalan and Carrie Bill Riley will provide an overview of the recent policy changes, highlighting the behavioral health service delivery opportunities these changes have created in FQHCs. Two examples are recent amendments to the Medicare FQHC regulations to allow FQHCs to bill for mental health virtual services at the PPS rate, and the continuing expansion in Medicaid of the certified community behavioral health clinic (CCBHC) program – with CCBHCs being promising care coordination partners for FQHCs in underserved communities. 

The presenters will provide sample key terms for CCBHC Care Coordination Agreements, and highlight compliance concerns associated with billing public programs for (and in some cases contracting with outside vendors to procure) behavioral health services. In addition to Medicare and Medicaid billing and program integrity issues, they will address Section 330 scope of project concerns relating to behavioral health.

Target Audience

  • Health Center CEOs
  • CFOs
  • COOs
  • Revenue cycle managers and billing managers

Learning Objectives

After this training, you will be able to:

  • Explain the rules for billing Medicare virtual mental health FQHC visits
  • Develop strategies for your health center to use newer Medicare offerings such as virtual communication services and care management to optimize behavioral health services for Medicare patients
  • Learn about considerations relevant to FQHCs as they interact with Medicaid CCBHCs, including care coordination and designated collaborating organization (DCO) arrangements, and guidance on dually certified FQHCs/CCBHCs
  • Identify compliance hotspots in the behavioral health arena, such as how to bill for and maximize payment for behavioral health services rendered to dual eligible beneficiaries that are covered under your state’s Medicaid FQHC benefit, but not under the Medicare FQHC benefit
Course summary
Available credit: 
  • 3.50 Certificate of Attendance
Course opens: 
Course expires: 


Susannah is a Partner in the firm’s health law practice group where she focuses on health care litigation and regulatory counseling, with a focus on Medicaid and Medicare payment, financing, and compliance issues. Susannah brings regulatory expertise to bear when advising clients and pursuing litigation on their behalf. She has experience negotiating Medicaid waivers and managed care arrangements on behalf of providers, provider associations, and governmental entities. She represented a group of providers in reaching a settlement in major Medicaid litigation. [Full Bio]


Carrie Riley is a Partner in the health law, non-profit and corporate law, and federal grants law practice groups. She counsels a wide variety of health care clients, including Title X grantees and subrecipeints, and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. Prior to going to law school, Carrie worked at a Title X regional training center for several years.  [Full Bio]

Brittney Rudolph

An Associate in the firm’s Health Care and Federal Grants practice groups, Brittney assists health centers, federal grant recipients, and other organizations on litigation matters and a range of transactional matters pertaining to contracting, regulatory compliance, fraud and abuse, and reimbursement matters. [Full Bio]

Certificates of Attendance: We verify attendance upon completion of a recorded training and will only issue certificates in the name of the account holder enrolled in the course. If you need to document attendance for someone other than the account holder, we provide blank Certificates of Attendance for a supervisor to sign and certify that a different individual viewed the course. 

Group Attendance: Due to the online nature of this training, we cannot verify participation by more than one person. For groups, we provide an attendance record form and blank Certificates of Attendance to record attendance at a group viewing session and document each individual's participation. We recommend that a supervisor or colleague sign the certificate to certify attendance. 

Read more about maintaining an attendance record in our FAQs.

Available Credit

  • 3.50 Certificate of Attendance


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