Policy & Strategy
Use the UIS/PPS Delay: How To Model Your 2027 Exposure Now
FQHC Talent Editorial Team
FQHC Talent
UPDATE (June 30, 2026): The worksheet still matters, but the date changed. The signed 2026-27 budget delays the major UIS/PPS clinic-payment reduction into a July 1, 2027 planning horizon. Do not borrow an outside local number unless you can verify it from primary materials. Build your own exposure model from your State-Only/UIS panel, visits by service line, current PPS rates, and applicable fee-schedule or managed-care rates.
Key Takeaways
- ✓Current status: the signed budget delays the major UIS/PPS clinic-payment reduction into a July 1, 2027 planning horizon.
- ✓Why it matters now: the delay is time to translate policy risk into your own verified panel, visit, rate, and site model.
- ✓What to do: Run the 7-step worksheet below now, subtract realistic offsets, and turn the result into a 2027 staffing and bridge plan with trigger points.
- ✓The honest part: a delay is only valuable if you use it. FQHCs that model now will make calmer, better decisions than those who wait for final remittances to tell them.
Planning horizon for your verified UIS/PPS exposure model
Confirm the final clinic-payment timeline against DHCS implementation guidance before making irreversible staffing decisions.
First, what the worksheet is modeling now
Today, when an undocumented Medi-Cal member — State-Only, also called UIS for Undocumented or Unsatisfactory Immigration Status — comes in for a visit, your FQHC bills the **PPS per-visit rate**: the encounter-based rate that reflects the true cost of an FQHC visit.
Earlier DHCS budget materials modeled a shift from PPS to the **standard Medi-Cal fee-schedule rate** for these visits. The signed budget delays the major clinic-payment reduction into a July 1, 2027 planning horizon. The worksheet below models that possible PPS-versus-fee-schedule exposure so you can use the delay window well.
That's the whole mechanic. The dollars come from one thing: **(your PPS rate − the new fee-schedule rate) × your UIS visit volume**, summed across every service line. Everything in this worksheet is built to fill in those blanks for your organization.
A word of caution before you start: **this guide does not give you rate numbers.** Your PPS rates are organization-specific, and the applicable fee-schedule rates vary by service and code.
Pull both from the authoritative sources — DHCS rate tables and your Medicaid Administrative Contractor (MAC) — and treat anything you can't verify there as a hole to fill, not a number to assume.
The 7-step UIS-PPS exposure worksheet
Work the seven steps in order. Steps 1–2 are about your own data; Steps 3–5 build the calculation; Steps 6–7 turn the gross figure into something you can actually plan around.
- **Step 1 — Pull your State-Only / UIS panel count.** How many of your patients are enrolled as State-Only / UIS members? This is your population at risk. Yours comes from your own eligibility / aid-code data.
- **Step 2 — Get annual visit volume by service line.** Break those patients' encounters into medical, dental, vision/optometry, and pharmacy. The change hits each line, so you need each line separately.
- **Step 3 — Look up your current PPS rate(s) and the applicable fee-schedule rates, per line.** Pull your current PPS rate and the applicable fee-schedule rate from the DHCS rate tables and your MAC — do not estimate these.
- **Step 4 — Compute the per-visit delta × volume, per line.** For each service line: (current PPS rate − new fee-schedule rate) × that line's UIS visit volume.
- **Step 5 — Sum the lines into your annual exposure.** Add the four line-level results. This is your gross annual UIS-PPS revenue exposure — the number your board needs from your own data.
- **Step 6 — Subtract realistic offsets.** Net the gross down by revenue and coverage you can actually capture (see the offsets section below).
- **Step 7 — Convert to a staffing & scenario plan with trigger points.** Translate the net number into a site-by-site revenue line and the decisions it forces — and pre-decide what triggers each one.
Now the detail on the two steps people get wrong: the table (Steps 3–5) and the offsets (Step 6).
Steps 3–5: Build the table
This is the engine of the whole exercise. One row per service line, one column for each input. Fill the rate columns from verified sources — leave them blank rather than guess.
Two reasons to keep the lines separate instead of running one blended number:
- **The delta is different per line.** Dental, vision, and pharmacy each have their own PPS-vs-fee-schedule gap. A blended rate hides which service line is bleeding most — and that's exactly the signal you need for Step 7.
- **Your offsets are line-specific too.** The Medicare care-management offset (below) lands on the medical and behavioral-health lines, not dental. Keeping lines separate lets you net the right offset against the right exposure.
| Service line | UIS visits (annual) | Current PPS rate | New fee-schedule rate | Per-visit delta | Annual delta |
|---|---|---|---|---|---|
| Medical | your count | from DHCS + MAC | from DHCS + MAC | PPS − fee schedule | delta × visits |
| Dental | your count | from DHCS + MAC | from DHCS + MAC | PPS − fee schedule | delta × visits |
| Vision / Optometry | your count | from DHCS + MAC | from DHCS + MAC | PPS − fee schedule | delta × visits |
| Pharmacy | your count | from DHCS + MAC | from DHCS + MAC | PPS − fee schedule | delta × visits |
| Total | = gross annual exposure |
Step 6: Subtract the offsets you can actually capture
Here's the part the statewide $1.6B headline leaves out: the gross number is not the net number. There are real, knowable offsets — and modeling them is how you turn an alarming figure into a plan.
Net your gross exposure down by:
- **New CY2026 Medicare care-management revenue.** The 2026 APCM and BHI codes can add Medicare care-management revenue when consent, cost-sharing notice, documentation, distinct-service, and local billing requirements are met. We broke down the implementation questions in our companion guide on the CY2026 Medicare care-management codes. Apply this modeled offset against your medical / BH exposure rows, not dental or pharmacy, and validate with billing/compliance before board use.
- **County backfill.** Some counties are funding local coverage for residents losing Medi-Cal. Monterey County's Esperanza Care is one named, public example of county-level mitigation. Check whether your county has a program — and whether your patients qualify — before you assume zero backfill.
- **Sliding-fee scale and grant revenue.** Your sliding-fee discount program and any wraparound grant dollars capture a portion of the visits that fall off PPS. This won't close the gap, but it changes the net.
Subtract these from your gross. **The result is the number you actually plan around** — and it's the honest one to bring to your board.
Your real planning number
Gross exposure − offsets = your real planning number. The offsets are smaller than the gap, but they are not zero — and they are the levers you control.
Step 7: Turn the number into a plan, not a worry
A number on a spreadsheet doesn't change anything. A number tied to decisions does. Once you have your net exposure, build the scenario plan:
- **Make it site-by-site.** A system-wide figure is for the board deck. A site-level figure is what tells you which clinic's staffing model is most exposed — usually the sites with the highest UIS panel share.
- **Set trigger points, not just targets.** Decide *in advance* what you'll do at each threshold. For example: "If realized Q3 collections on UIS visits come in more than X% below model, we pause the dental hire at Site B." Pre-deciding beats reacting to the first bad remittance.
- **Sequence the offsets.** Stand up the CY2026 care-management billing during the delay window so the offset is live before any UIS/PPS implementation date — not three quarters later.
- **Track final guidance.** The budget agreement changed the working timeline, but DHCS implementation details still control the operational answer. Check the May Revision tracker and final DHCS guidance before you finalize the model.
This is the move that matters: translate a statewide policy abstraction into your own patients, your own visits, and your own revenue line. That's what lets a leadership team act with clarity instead of dread.
Try our free tool
Use the Intelligence Dashboard to track the 2027 UIS/PPS planning horizon alongside every funding cliff, budget vote, and policy development affecting California FQHCs.
The bottom line
**The date moved; the modeling obligation did not.** The math is simple even if the dollars are hard: pull your UIS panel, break visits out by service line, get your verified PPS and fee-schedule rates, multiply the delta by volume, sum it, then net out the CY2026 care-management offset, county backfill, and sliding-fee capture.
Statewide exposure estimates can size the risk, but your number is yours to find.
The FQHCs that find their number early will plan calmly while everyone else waits for the remittances to tell them. Run the seven steps. Put your number on it.
When you're ready to put it in the larger picture, the value-based-care hub and the companion care-management guide show how the offset side of this equation connects to everything that comes next.
Sources
- California Department of Health Care Services (DHCS) — DHCS. State-Only / UIS resources, Medi-Cal provider rate tables, and forthcoming final implementation guidance.
- California Health Care Foundation — CHCF. Statewide community health center exposure context; use as a sensitivity baseline, not as final implementation timing.
- The CY2026 Medicare care-management codes — FQHC Talent. Companion guide on how to bill APCM and the BHI add-ons — the Medicare revenue offset on the medical / BH side.
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