We Don’t Want to Pay for That: Recent Strategies Employed by State Medicaid Agencies to Limit FQHC Payments and What to Do About It

March 1, 2024

Access the on-demand webinar here. 

This webinar will address developing and concerning trends in FQHC reimbursement and why the foundation of any good payment reform initiative is a properly set PPS rate.  Many states have started employing similar strategies to limit FQHC payments via the change in scope of services process, often citing budget shortfalls as the reason why rates cannot increase. Such strategies include rate limits based on such devices as a percentage of average (such at 105% of the average rate across the state), productivity standards (the famous 4200 visits per year even though that number was disavowed by HRSA 30 years ago), and limits on administrative costs.

States have also defined and redefined their rules on what is a qualifying event (usually writing out “duration, intensity and/or amount” of services from the definition of changes in the scope of services and only leaving a new type of service as qualifying) to make any qualifying changes very hard to meet. Other strategies include percentage increase requirements and refusing to include as allowable costs such things as outreach, case management and care coordination. Finally, despite at least one favorable court decision, many states refuse to pay up to the Medicaid rate for full dual eligibles and only pay the Medicare co-pay.

Our speakers, Ted Waters and Kathy Ghiladi, two attorneys with extensive experience in Medicaid payment issues, will discuss why failing to address these issues sets the stage for long-term and devastating shortfalls in revenue, with all the attendant problems that come with underfunding, and what the federal rights of FQHCs are for full and accurate Medicaid payments. 

Target Audience

  • Heath Center C-suite (CEOs, COOs, CFOs, and Compliance Officers)
  • Health Center finance personnel
  • Primary care association personnel
  • Billing personnel
  • Revenue cycle personnel

Learning Objectives

After this webinar, you will be able to:

  • Understand the Federal law requirements and the policy behind them
  • Understand the rationale for why budget limitations are not lawful
  • Develop strategies to move towards a compliance system in your state
  • Develop strategies to put your center(s) in the best position to prevail in an administrative hearing or in federal court
Course summary
Available credit: 
  • 1.50 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
03/01/2024 - 1:00pm EST
Event ends: 
03/01/2024 - 2:30pm EST

Kathy Ghiladi

Kathy Ghiladi is a Partner in the firm's Health Care practice group. Her practice focuses on government-sponsored health care programs such as Medicaid, CHIP, Medicare, and the Affordable Care Act, with an emphasis on payment/reimbursement and compliance related issues. Kathy also represents clients in government investigations and audits, litigation before federal and state courts, as well as in administrative appeals with the U.S. Department of Health and Human Services Departmental Appeals Board (DAB) and Provider Reimbursement Review Board (PRRB). She provides reimbursement counseling (including identification, reporting, and repayment of overpayments) with respect to Medicare, Medicaid, and private third-party payors.  [Full Bio]

Ted Waters

Ted Waters is Managing Partner of the firm and a member of the Health Care and Federal Grants practices. Ted is a national authority in the area of federal grants, particularly in the health and community service spheres. He advises clients on all aspects of program requirements, including issues such as cost-based reimbursement, governance, grant administration, cost reporting, and administrative issues and routinely handles challenging issues such as government audits, internal investigations, and litigation. His priority is to help each organization carry out its mission by offering practical, down-to-earth counsel and to ensure that legal challenges do not distract from that focus. [Full Bio]

Participants can earn up to 1.80 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 6 of the polling questions during the webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, we will email you your CPE Certificate within two (2) weeks.


  • Prerequisites: None 
  • Target Audience: Heath center C-suite (CEOs, COOs, CFOs and Compliance Officers), health center finance personnel, primary care association personnel, billing personnel, and revenue cycle personnel
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to six (6) out of eight (8) polling questions.

Feldesman Leifer LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

Available Credit

  • 1.50 Certificate of Attendance


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Access to the recorded version of this webinar is included in your purchase.

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