Legislation

The work-requirement map, 6 months out: 4 states going early, Nebraska's freeze is the preview, and Georgia's 5% enrollment rate is the warning

With the CMS-2454-IFC comment period closing July 31 and full implementation due January 1, 2027, the state map has taken shape. Four states are going early: Nebraska (enforcing since May 1), Montana (July 1), Arkansas (soft launch July 1), and Iowa (December 1, with no high-unemployment hardship exception) — plus Idaho (Dec 31 statutory deadline with the nation's longest 3-month lookback) and Kentucky (HB 2's pre-enrollment proof requirement, enacted over the governor's veto). Nebraska's 'soft start' is producing the first hard national data: ZERO new Medicaid enrollees in May versus a typical ~15/month at the state's health centers (a pure chilling effect — termination checks don't even begin until July 31), with 20,000-28,000 of ~70,000 expansion enrollees flagged for documentation. Georgia's Pathways — the only mature work-requirement program — has enrolled ~16,183 people in three years, about 5% of its potential population. Two mitigations worth copying: Utah exempted homeless individuals (FQHC-designed, NACHC-endorsed), and Oregon exempted FQHC visits from new cost-sharing. The operational takeaway repeats Nebraska's lesson everywhere: the chilling effect arrives before the disenrollments do, and clinics' navigation capacity is the rail it all runs on.

MACPAC's June report hands FQHCs two federal hooks: a work-requirement monitoring mandate and a human-review requirement for AI prior-auth denials

MACPAC — Congress's independent Medicaid advisory commission — voted 15-2 to recommend that CMS publish a transparent monitoring and evaluation plan for the H.R. 1 community-engagement (work) requirements before the January 1, 2027 implementation, anchored on minimizing administrative burden, timely public state data, and measuring actual employment and health outcomes. The same June 2026 report cycle carries four recommendations on automation in Medicaid prior authorization: every adverse PA determination must be reviewed by a human with relevant clinical expertise (automation alone cannot deny), CMS must extend the same rule to fee-for-service, issue managed-care AI oversight guidance, and require MCOs to disclose AI use to states. For FQHCs juggling 10-20 Medicaid MCO contracts, the human-review recommendation is the federal counterweight to algorithmic denial engines — and the monitoring framework gives state PCAs the yardstick to hold their Medicaid agencies to as work requirements roll out.

Washington's 340B protection law survives — and the national map now splits clean: 22 state laws, two circuits upholding, one blocking, DOJ siding with manufacturers

On June 9, 2026 a federal judge denied AbbVie, AstraZeneca, Novartis, and PhRMA's bid to block Washington's SB 5981, letting the nation's 22nd state 340B contract-pharmacy protection law take effect June 10 with penalties up to $5,000/day. The ruling sharpens the cleanest circuit split in health law: the 5th Circuit upheld Louisiana's law (Feb 9) and Mississippi's in two separate cases (Apr 9), Minnesota's state appeals court upheld its law (Feb 17) — while the 4th Circuit blocked West Virginia's as likely federally preempted (Mar 31) and a North Dakota judge struck that state's law in April. Two more wrinkles tilt the field: the Trump DOJ filed amicus briefs in the Colorado and Rhode Island cases (Feb 2026) backing the manufacturers' preemption theory — a first — and Kansas becomes the only state moving backward, its protections expiring June 30 after the renewal bill died. Multiple law firms now expect Supreme Court review. For multi-state FQHC networks, 340B contract-pharmacy security now varies by federal judicial circuit; the NACHC state-law tracker is the canonical map.

Becerra Tops the June 2 Governor Primary and Advances to November — Putting a Former HHS Secretary in Reach of the Office, but Not Until After the December Cliff

In California's June 2 top-two primary, Democrat Xavier Becerra — former U.S. HHS Secretary and former California Attorney General — finished first for governor (~27%) and advanced to the November 3 general election; the second spot was still being decided between Republican Steve Hilton (~26%) and Democrat Tom Steyer (~22%) as millions of ballots remained uncounted (certification ~July 10). Becerra is the most Medicaid-literate candidate imaginable for FQHCs: he ran HHS (which oversees CMS and HRSA) and litigated California's health-coverage fights as AG. He has walked back single-payer in favor of 'immediate wins,' pledged a day-one executive order to maintain coverage continuity for Californians hit by federal cuts, and emphasized fully implementing Proposition 35 to dedicate MCO-tax revenue to Medi-Cal — though critics note he has not specified how to fund a ~$30B/yr federal funding gap. Rob Bonta (D) also advanced for Attorney General (~55%), signaling continuity in California's legal defense of Medi-Cal and 340B. The crucial caveat for FQHC planning: the next governor is not sworn in until January 2027 — so the December 31, 2026 'triple cliff' and the June 15 budget land on Newsom's watch, not the winner's. The primary signals continuity-over-disruption on health policy, not near-term relief.

California Budget Deadlocks 11 Days Before the Deadline — Senate Wants a $285/Employee Fee Instead of Renewing the $4.5B MCO Tax That Funds Medi-Cal Rates

As of June 4 — with the June 15 constitutional budget deadline 11 days out — Governor Newsom and the Assembly (who want to renew the long-standing Managed Care Organization tax, ~$4.5B/year) are deadlocked with the state Senate, which instead proposes a new $285/employee/month fee on large employers for each worker enrolled in Medi-Cal. The MCO tax expires December 31, 2026; it is the mechanism California uses to draw down federal matching dollars that fund the Medi-Cal primary-care, maternal-care, and non-specialty behavioral-health rate increases — the rate floor FQHCs rely on to supplement non-PPS revenue. The Senate's employer-fee substitute would raise less and carries its own federal-approval risk on top of the LAO's warning that the two-component MCO renewal is 'novel and risky.' H.R. 1 and Prop 35 already shrink any successor tax. For FQHC CFOs the risk is concrete: a botched renewal — or a skeleton budget passed to meet June 15 — leaves the Medi-Cal rate floor uncertain at the same moment as the July 1 UIS-PPS cut and the January 2027 Medicaid work requirements.

CMS Publishes the Medicaid Work-Requirements Rule (CMS-2454-IFC) — 80 Hours/Month, Effective July 31, States Must Implement by Jan 1, 2027

On June 1, 2026 — ahead of its June statutory deadline — CMS issued the interim final rule implementing H.R. 1's Medicaid 'community engagement' (work) requirement. Adults in the expansion group must document 80 hours/month of qualifying activity (employment, work programs, community service, or at-least-half-time education) — or earn roughly $580/month — to keep coverage. The rule is effective July 31, 2026 (the comment period closes the same day), states must begin member outreach by August 31, and full implementation is required by January 1, 2027; it also tightens illness/incapacity exemption eligibility. The Commonwealth Fund estimates 5.6 million community-health-center patients are exposed nationwide. This is the operational floor FQHCs in both California and Texas have been waiting on: it converts the abstract 'work requirement' into a concrete navigation problem — every center now has roughly four weeks to finalize its eligibility-redetermination and patient-navigation playbooks before the state outreach window opens. The rule resolves the platform's two prior 'watch' items (it was due; it is now published).

CMS Interim Final Rule on Medicaid Work Requirements Published June 1 — Defines Exemptions, Reporting, and Enforcement

CMS published an Interim Final Rule (CMS-2454-IFC) on June 1, 2026 defining critical work requirement implementation details: exemption criteria, reporting mechanisms, compliance verification, and non-compliance consequences. The 80-hour/month requirement scope depends entirely on this rule — narrow exemptions could mean millions losing coverage, broad exemptions could limit damage. States must conduct member outreach June 30–August 31, 2026. CMS is distributing $200M in 'Government Efficiency Grants' for state tracking systems, but no direct funding flows to FQHCs despite bearing the patient-facing burden.

HHS Medicaid Work-Requirements Interim Final Rule Published June 1 — FQHC Eligibility Teams Need a Playbook Now

HHS published the Interim Final Rule (CMS-2454-IFC) implementing H.R. 1's Medicaid community-engagement (work) requirements on June 1, 2026. The rule will define operational standards: verification methods, qualifying activities, exemption criteria, and how the 80-hr/month threshold is measured. States must then conduct mandatory member outreach between June 30 and August 31, 2026, ahead of the December 31, 2026 implementation deadline. Commonwealth Fund estimates 5.6M CHC patients are at risk of losing Medicaid under this framework. Strategic implication: FQHC eligibility and enrollment teams have ~30 days from rule publication to retrain staff before the June 30 state-outreach window opens. Late or vague guidance = redetermination chaos in FQHC navigation workflows starting July 1. CA's outreach burden is one of the largest in the country (~5M expansion enrollees). Pair with CHAI/NACHC Medicaid-eligibility AI Best Practice Guides (already tracked) — those provide the AI guardrails; this rule sets the legal floor.

California's 4-Bill H.R. 1 Mitigation Package Advances — Cost-Sharing Cap, Retroactive Coverage, Renewal Automation, Disenrollment Dashboard

A four-bill California package designed to blunt H.R. 1's Medi-Cal damage advanced through Appropriations (May 14) and onto floor votes the week of May 22-26 — co-sponsored by Western Center on Law & Poverty, Justice in Aging, the National Health Law Program, and Health Access California. AB 2208 (Stefani) passed the Assembly 58-19 on May 26: it caps H.R. 1-triggered Medi-Cal cost-sharing at 1 cent per service and restores the full 3-month retroactive coverage window with state funds (H.R. 1 cut it to 1 month for expansion adults). Retroactive coverage is a direct FQHC revenue protection — it lets centers bill for care delivered before eligibility is finalized. AB 2201 (Boerner) automates Medi-Cal renewal verification to reduce churn from H.R. 1's new 6-month redetermination cycle. SB 1202 (Weber-Pierson) requires DHCS to publish a public dashboard tracking H.R. 1-attributable disenrollments — official data FQHCs can use to quantify coverage loss in their service area. Strategic implication for CA FQHCs: AB 2208's retroactive-coverage restoration is the most balance-sheet-relevant; track all four through the second house and the June budget.

AB 403 Would Force DHCS to Publicly Report CHW/Promotora Medi-Cal Use — After Fewer Than 6,000 of 15M Beneficiaries Accessed the Benefit

AB 403 (Asm. Liz Ortega, D-20) — the Community Health Worker/Promotora/Representative Medi-Cal Services Transparency Act — would require DHCS, beginning July 1, 2027, to publish an annual analysis of CHW Medi-Cal benefit utilization, reimbursements, and CHW/beneficiary demographics. The driver: of roughly 15 million Medi-Cal beneficiaries, fewer than 6,000 have accessed CHW services and under $1 million has been reimbursed since the benefit launched — evidence the benefit is badly underused. Co-sponsors: Latino Coalition for a Healthy California, California Pan-Ethnic Health Network, Visión y Compromiso, and The Children's Partnership. Strategic implication for FQHC leaders: FQHCs are the primary CHW/ECM billing providers, so mandated public reporting will surface site-level CHW utilization and strengthen the advocacy case for raising the CHW Medi-Cal rate. This is distinct from SB 184 (CHW certification). The bill is advancing through the 2025-26 session; May 29 is the house-of-origin passage deadline.

CA AB 2756 Would Force DHCS to Publicly Report Medi-Cal Vision Quality — After Data Shows Only 16% of Medi-Cal Kids Got Eye Care

AB 2756 (Ahrens), sponsored by the California Optometric Association, passed the Assembly floor 78-0 on May 26, 2026 and now moves to the Senate. It would require DHCS to establish and publicly report equity-stratified Medi-Cal vision quality, access, and utilization measures with annual benchmarks. The bill follows an April 2, 2026 CalMatters/COA report finding only 16% of school-age Medi-Cal children received eye care in 2022-24 (down from 19%), declines in 47 of 58 counties, and a ~$47 comprehensive exam rate unchanged for 25 years — leaving only ~10% of COA optometrists accepting Medi-Cal. Strategic implication for FQHC leaders: (1) FQHCs are core Medi-Cal pediatric vision providers — mandated DHCS reporting will surface site-level performance and raise screening/referral expectations; (2) the rate-stagnation spotlight strengthens the case for vision-service revenue investment (see our Vision Care briefing); (3) pair AB 2756 advocacy with the stalled NHSC Improvement Act (HR 920/S.1445) that would restore optometrist NHSC eligibility for recruitment; (4) FQHCs with optometry should benchmark their pediatric eye-exam rates now, ahead of public reporting.

LA Measure ER on June 2 Ballot — 'Essential Services Restoration Act' Polling 45/47 Against, 12 Days to ~$1B/yr Safety-Net Backfill Vote

Los Angeles County Measure ER — officially the 'Essential Services Restoration Act for Los Angeles County' — heads to voters June 2, 2026 with polling showing 47% opposed vs. 45% in favor. The half-cent sales tax (0.5%) for 5 years (Oct 2026 → 2031) generates ~$1B/year for safety-net hospitals and clinics. Exclusions: groceries, prescription drugs, medical equipment. If it fails: LA County FQHCs lose key state/local backfill against ~$1.5B in federal cuts; KFF reports DHS's $6.5B budget is 70% Medicaid-dependent with $750M revenue loss by FY2027-28 (~10% revenue loss); some LA clinic networks could lose 20% of annual budget. Strategic implication for LA FQHC executives: (1) Mobilize patient/community voter education TODAY — 12-day window; (2) Brief boards on Plan B scenarios for failure case (Sept 2026 budget revisions, layoff timing, sliding-fee expansion costs); (3) Coordinate get-out-the-vote with CCALAC's 450+ LA County health center site network; (4) Engage AltaMed, St. John's, LA LGBT Center, Eisner, Watts, Venice Family, Northeast Valley, T.H.E., El Proyecto, Clinica Romero on coordinated messaging before June 2.

CalAIM 1115 Waiver Renewal Pending CMS Approval — $1.2B/yr ECM Funding on Dec 31, 2026 Cliff

California's CalAIM 1115 waiver renewal application comment period closed March 12, 2026, with the existing waiver expiring December 31, 2026. CMS approval is pending — the May 2026 to August 2026 window is the decision pipeline. Without renewal, approximately $1.2B/yr in Enhanced Care Management (ECM), Community Supports, and CalAIM transformation funding disappears — threatening thousands of FQHC care coordination, CHW, housing navigator, and care manager positions. Combined with the December 2026 CR cliff for Community Health Center Fund ($4.6B/yr) and Health Resources and Services Administration appropriations, FQHCs face a structural dual December 2026 funding cliff. Strategic implication for FQHC CFOs and program directors: (1) Stress-test FY27 budgets under a 'no CalAIM' scenario, (2) Identify which ECM staff positions are CalAIM-funded vs. PPS-funded, (3) Build a Plan B for housing navigator and CHW roles dependent on Community Supports funding, (4) Engage CPCA and CCALAC for early intelligence on CMS approval signals.

LA Measure ER on June 2 Ballot — $1B/Year Sales Tax for FQHCs + Public Hospitals, Polling Shows 47% No / 45% Yes

LA County Measure ER — a half-cent sales tax raising the county rate to 10.25% — appears on the June 2, 2026 ballot. Projected revenue: $1B/year for Medi-Cal providers (FQHCs and public hospitals) through 2031. May polling shows 47% opposed, 45% in favor — a narrow margin with 8% undecided. If passes: largest local healthcare tax in LA County history with 9-member oversight committee + Auditor-Controller audits. If fails: zero local backfill against federal Medicaid cuts. Strategic implication: every LA FQHC (AltaMed, St. John's, Eisner, Northeast Valley, Watts, KHEIR, LA LGBT Center, Harbor, APHCV, El Proyecto) has revenue at stake. Coalition behind the measure includes 'Restore Healthcare for Angelenos' (already tracked). This is the most consequential FQHC funding event in LA County in years — and the 22-day window between today and election day is the highest-leverage period for FQHC executives to amplify pro-Measure-ER messaging through staff, board, and patient channels.

AB 108 Signed — $25M Emergency Grants for Distressed Hospitals + Senate Proposes $200M Expansion (Precedent for FQHC Liquidity Grants)

Governor Newsom signed AB 108 in early May 2026, creating a $25M one-time emergency grant fund for distressed hospitals (eligibility: nonprofit/public, <10 days cash on hand, exhausted other options, >50% Medi-Cal/uninsured patient base). Senate budget proposal adds $200M for FY2026-27. While criteria currently target hospitals not FQHCs, this is the precedent CPCA and NACHC have been arguing for: a state-level emergency liquidity backstop for safety-net providers. Strategic implication for CA FQHCs: (1) CPCA should push to extend distressed-provider grant logic to FQHCs in the FY2026-27 budget conference; (2) FQHCs already on cash-flow watch should document <10-day cash positions, exhausted-options narratives, and >50% Medi-Cal/uninsured exposure for future eligibility arguments; (3) watch the Senate $200M expansion for FQHC inclusion language. The bill establishes the political logic that California will not let safety-net providers fail in the H.R. 1 era. Pairs with the BHCIP $5.8B announcement as the 'California is building backstops' narrative — important for staff retention and board confidence.

Federal Government Appeals 340B Child Site Ruling — FQHC Site-Expansion Strategies Back in Legal Limbo

The federal government has appealed the March 3, 2026 district court ruling that struck down HRSA's 340B child site registration requirement. The original ruling let 340B child sites access discounts immediately upon opening — without waiting for Medicare cost report filing and HRSA database registration. That was a significant operational win for FQHCs expanding sites (especially during the H.R. 1 site-multiplication strategy CFOs have been pursuing). An appeal could reverse that win, force FQHCs back to delayed eligibility (potentially 6-18 months of delayed 340B savings on new sites), and disrupt FQHC site-expansion strategies. The government may also seek a stay during appeal — which would effectively pause the favorable ruling while the appellate court considers it. Strategic implication: any FQHC that announced or is mid-flight on new site openings should immediately: (1) document existing 340B savings projections, (2) prepare contingency revenue forecasts assuming delayed eligibility, (3) coordinate with NACHC for amicus support if the appellate timeline accelerates. Pairs with the 4th Circuit contract pharmacy ruling already tracked — 340B litigation is a constant moving target through 2026.

Newsom May Revision Drops Mid-May 2026 — FQHC Watch Items: H.R. 1 Absorption, MCO Tax, Prop 35 Allocations, Worker Reqs Cost

California Governor Newsom's FY2026-27 May Revision is expected mid-May 2026, his last gubernatorial budget. The January proposed budget projected a $2.9B deficit and $1.1B in net Medi-Cal cost pressure from H.R. 1 absorption. Items every CA FQHC executive should track in the May Revision: (1) Final UIS PPS-to-FFS transition codified for July 1, 2026, (2) MCO Tax permanence framework via Prop 35 allocations to FQHC PPS supplemental rates, (3) work/community engagement requirements ($102.4M cost reduction via Jan 1, 2027 effective date — administrative cost shift to counties), (4) federal admin match cut from 50% to 25% (Oct 2026), and (5) any capacity expansion for the $233.6M Rural Health Transformation funding. The May Revision typically signals where the Legislature has political room to push back vs. accept cuts. CPCA + CCALAC + Health Access advocacy posture for the May 2026-July 2026 budget cycle is the single most consequential window of the year for FQHC revenue.

Hospitals File Emergency Court Order to Block 340B Rebate Pilot — Third Litigation Front Opens

Hospital plaintiffs filed an emergency motion in late April / early May 2026 seeking an injunction against HRSA's 340B Rebate Model Pilot Program, alleging irreparable harm. This is the third litigation front against the rebate model: (1) the AHA/MHA Maine District Court case that already vacated the original rebate notice in February 2026, (2) the AHA en banc petition in the 4th Circuit on the WV contract pharmacy law, and now (3) this emergency injunction filing. The HRSA RFI (April 20) and ICR (April 27) comment periods both closed with industry-unified opposition (AHA, NACHC, ASHP, WHA all filed). HHS is now in review phase before any pilot relaunch. If the emergency motion succeeds, the rebate pilot is frozen nationally — direct cash-flow protection for FQHC pharmacy economics. If it fails, FQHCs face the prospect of paying full price upfront with 30-90 day rebate lag. CA FQHCs heavily 340B-dependent (AltaMed, FHCSD, San Ysidro, Vista Community Clinic, Asian Health Services, La Clinica de la Raza) should be running both scenarios in their FY26-27 cash flow projections. Pairs with the AbbVie 340B patient-definition lawsuit (April 8) and the Lilly/Novo claims-data mandate already active.

Bipartisan H.R. 8629 Would Build the FQHC Workforce Pipeline — NHSC Priority, Loan Repayment, CHW & Behavioral-Health Hiring

Reps. Raul Ruiz (D-CA-25) and Gus Bilirakis (R-FL) introduced the 'Developing the Community Health Workforce Act of 2026' (H.R. 8629) on April 30, referred to House Energy & Commerce and Ways & Means. It is the federal supply-side counterpart to H.R. 1's demand-side Medicaid cuts: it gives FQHCs and RHCs priority for National Health Service Corps assignments, expands loan repayment, funds health-center workforce pipelines and CHC–hospital GME partnerships, and grows the interdisciplinary behavioral-health workforce (physicians, nurses, social workers, community health workers, pharmacists). It is early-stage (committee referral), so it is a watch item — not law — but it signals bipartisan federal intent to shore up the FQHC labor supply just as California's CHW Medi-Cal benefit (AB 403) and the December 2026 funding cliff put workforce front and center. Note: this is a distinct, real Ruiz bill, not to be confused with the phantom '340B' bill that circulated earlier.

CPCA + Open Door File Federal Lawsuit to Block SEIU-UHW 90% Mission-Spend Ballot Measure — Federal Preemption Argument

The California Primary Care Association (representing 2,300+ clinics) and Open Door Community Health Centers (Humboldt/North Coast FQHC) filed a federal lawsuit on April 30, 2026 in the U.S. District Court for the Northern District of California seeking to block Initiative #25-0008 — the SEIU-UHW-sponsored ballot measure requiring CA health clinics to spend at least 90% of revenue on patient care. The complaint argues the measure: (1) interferes with federal HRSA Section 330 spending requirements which already prescribe how FQHC grant funds are used, (2) is preempted by the National Labor Relations Act (NLRA) because it would dictate the financial terms of labor disputes, (3) violates the First Amendment by compelling specific spending allocations. SEIU-UHW spokesperson Renée Saldaña called it 'a desperate attempt by the clinic industry to avoid accountability.' This is the FIRST federal preemption suit against an FQHC-targeted ballot measure and runs in parallel with the AB 1113 legislative track (90% nonprofit mission spend bill already advancing). SEIU-UHW submitted ~1M signatures — nearly 2× the 546,651 threshold — making qualification a near-certainty unless courts intervene. Open Door (70% Medi-Cal patients, rural North Coast) joining as named plaintiff signals that small rural FQHCs view the measure as existential. Strategic implication: ruling on preliminary injunction expected before Secretary of State certification (early summer 2026). Watch for parallel AB 1113 Assembly Appropriations hearings.

CPCA + Open Door File Federal Lawsuit (N.D. Cal.) to Block SEIU-UHW 90% Mission-Spend Ballot — Federal Preemption Argument

California Primary Care Association (representing 2,300+ clinics) and Open Door Community Health Centers filed a federal lawsuit in the Northern District of California April 30, 2026, asking the court to preempt the SEIU-UHW 90% patient-care spending ballot initiative on grounds it conflicts with HRSA Section 330 grant requirements, federal nonprofit governance laws, and PPS reimbursement framework. Major escalation: CPCA shifting from political opposition (already-tracked AB 1113 coalition + CCALAC counter-ballot) to legal preemption strategy. The SEIU-UHW initiative now faces 4 simultaneous opposition tracks: counter-ballot (CalChamber Affordable California 1M signatures), legislative (AB 1113 industry-led oversight), legal (today's federal suit), and political messaging. Strategic implication: every CA FQHC executive should know whether their organization joined as a co-plaintiff or remained on the sidelines — that public posture will shape board, donor, and labor relations through November 2026.

California Senate Advances SB 915 + SB 1323 — ICE Restrictions in Hospital and FQHC Patient Rooms; Bills Clear Health and Judiciary Committees

SB 915 (Menjivar) prohibits 'blackout policies,' bars ICE agents from patient rooms without legal authorization, requires staff to document refusals, and bans agents from making medical or interpretation decisions. Companion bill SB 1323 (Rubio) requires staff to help detained patients notify families. Both passed Senate Health and Judiciary along party lines and head to Senate Appropriations. ER physician SatKartar Khalsa testified ICE has 'instilled fear in our hospitals and has kept us from doing our job.' Direct operational impact: every California FQHC needs new protocols for ICE encounters, staff training, and documentation procedures. Combine with existing immigration-status protections under HIPAA and CA Civil Code §1798.99.10.

HRSA 340B Rebate Model RFI — Comment Deadline April 20

HRSA's Request for Information on the 340B rebate model closes April 20, 2026. FQHCs have a narrow window to shape how manufacturer rebates, contract pharmacy oversight, and documentation requirements are structured. Combined with 2026 Data Request List changes tightening contract pharmacy scrutiny, this deadline is the single most consequential 340B policy window of the year. NACHC is mobilizing comments.

HRSA 340B Rebate Model RFI: Comment Deadline April 20 — Possible Expansion to All IRA Drugs

After a Maine federal court vacated the original 340B rebate pilot program, HRSA is gathering stakeholder input with a 60-day comment window closing April 20. HRSA has signaled it may expand the rebate model to ALL drugs selected for Medicare price negotiation under the IRA through 2027. FQHCs that depend on 340B upfront discounts for cash flow could face a shift to delayed rebate payments — a devastating change for smaller FQHCs without reserves.

SB 1422 Committee Hearing April 20 — Bill to Restore Full Medi-Cal for Undocumented Adults Faces Critical Gate

Sen. Durazo's SB 1422 — which would restore full Medi-Cal eligibility for undocumented adults, reversing the January 2026 enrollment freeze — reaches its first committee hearing April 20, 2026. CPCA and health center advocates are expected to testify. If the bill advances, FQHCs could see UIS patient revenue restored by 2027; if it stalls, the PPS payment elimination for undocumented patients is entrenched through at least the end of the current legislative session.