Legislation

No Optometry Scope or Laser Bill Exists in California's 2025-26 Session — an Absence Established by Enumeration, Not by Failing to Find One

This entry publishes a NEGATIVE finding on purpose, because an unrecorded absence gets re-chased every cycle. Prior sessions repeatedly hunted for a current California optometry scope-expansion or laser-privileges bill on the strength of advocacy-page signals, and repeatedly could not confirm a bill number. The question is now settled the only way an absence can be settled: by enumerating the SUBJECT field of all 18,444 bill-version records in the Legislature’s own bulk data for the 2025-26 session. No optometry scope or laser bill appears. WHAT THIS DOES AND DOES NOT MEAN: it means no such bill is pending as of this review, so an FQHC planning vision staffing should not assume a scope change is coming this session. It does not mean optometry scope is settled policy, that a bill cannot be introduced in a future session, or that gut-and-amend cannot repurpose an existing vehicle late in a session. The operative California scope authority remains AB 407 (operative 2022). Re-run the enumeration rather than a keyword search before publishing any future claim that a scope bill is or is not moving.

California AB 2756 passes the Legislature and moves to enrollment — Medi-Cal vision reporting is proposed, not yet law

The California Senate passed AB 2756 39-0 on August 20, 2026, and the Assembly concurred in Senate amendments 78-0 on August 24. The official history now lists the bill in engrossing and enrolling. The bill would require DHCS to establish and publicly report Medi-Cal vision quality, access, and utilization measures. Boundary: passage by the Legislature is not enactment, and the cited history establishes no new FQHC payment, patient entitlement, site-level performance result, compliance date, or staffing effect. Those remain unconfirmed until gubernatorial action and implementation guidance.

S. 5244, the SUSTAIN 340B Act, is introduced and referred to Senate HELP — its pilot sunset remains a proposal

GovInfo identifies the August 5, 2026 proposal as S. 5244, introduced by Sen. Moran with Sens. Baldwin, Capito, Kaine, Boozman, and Hickenlooper, read twice, and referred to the Senate Committee on Health, Education, Labor, and Pensions. The introduced text proposes contract-pharmacy, patient-definition, clearinghouse, reporting, audit, and other 340B changes. Section 5 would require HHS—only after enactment—to conclude the 340B Rebate Model Pilot within one year, not expand it, discontinue it at one year, and transition to the proposed data clearinghouse. As of the August 29 review, GovInfo lists an introduced bill, not enacted law: the introduction changes no current 340B rule, patient definition, contract-pharmacy duty, or pilot status. Separately, HRSA's revised pilot notice, published August 3 at 91 FR 48883, set an August 24 manufacturer-plan submission deadline and a planned January 1, 2027 effective date for approved plans covering selected drugs. Submission is not approval, and the current HRSA pilot page reviewed does not publish an approved-plan list. Continue to use current law and current HRSA materials unless Congress enacts legislation or HRSA publishes a later agency action. Date trap: this bill reuses the name of the February 2, 2024 SUSTAIN 340B proposal; verify S. 5244, the 2026 sponsor list, and current status before citing it.

Federal court denies preliminary relief without prejudice in the Medicaid community-engagement rule challenge; merits remain unresolved

On July 29, 2026, the U.S. District Court for the District of Massachusetts denied without prejudice the states' motion for a preliminary injunction in Commonwealth of Massachusetts v. Oz, No. 1:26-cv-12962-RGS. The court resolved only the irreparable-harm factor: it cited the federal government's representation that 90% of state eligibility-system implementation costs would be reimbursed and found the remaining asserted costs insufficient for extraordinary preliminary relief. The order expressly says the denial does not reflect or predict the court's view of the merits and preserves a later request for emergency relief in stated circumstances. The challenged provisions concern the medically-frail definition, a 12-month lookback for medical-frailty claims, and the imposition of a work requirement on the short-term-hardship Emergency Declaration exception. CMS-2454-IFC became effective July 31, while the rule generally requires state implementation by January 1, 2027. This procedural ruling does not establish a uniform state outreach month, a person-level eligibility result, or a measured number of FQHC patients who will lose coverage. FQHC teams should use current CMS and state notices, escalate eligibility questions through approved channels, and keep disability, employment, income, immigration, and clinical information out of FQHC Talent.

HHS strips disparate-impact liability out of its Title VI regulations — final rule, effective the day it published, no comment period; 45 CFR part 80 binds every Section 330 grantee

HHS published a final rule July 24, 2026 (FR 2026-15000, RIN 0945-AA29) amending 45 CFR part 80 — its Title VI regulations — to remove provisions imposing liability based on unintentional DISPARATE IMPACT, conforming to Executive Order 14281. It is a Rule, published and EFFECTIVE the same day, with no comment period — HHS issued it without prior notice and comment, invoking the APA §553(a)(2) grants-and-contracts exception after the Richardson Waiver's rescission. The rule removes and reserves 45 CFR 80.3(b)(2) — the general prohibition on using 'criteria or methods of administration which have the effect of subjecting individuals to discrimination... because of their race, color, or national origin' — and also 80.3(b)(6), 80.3(c)(3), 80.5(g), 80.5(i) and 80.5(j), while revising 80.3(b)(3) and 80.5(h). WHY IT REACHES HEALTH CENTERS: part 80 binds every recipient of HHS federal financial assistance, which includes every Section 330 grantee. THIS IS WHERE IT IS EASY TO OVERSTATE. The rule text never mentions health centers, FQHCs, Section 330 or Medicaid, and never mentions LEP or 'limited English proficiency'. The relevance is structural — it runs through part 80's reach over grantees, not through anything the rule says about health centers. Critically, SECTION 1557 IS NOT MENTIONED AND IS NOT TOUCHED by this rule, and neither are California's Dymally-Alatorre Act or Medi-Cal contract language-access requirements. Anyone telling you this rescinds your language-access obligations is inferring, not reading — Title VI's LEP framework does rest substantially on national-origin disparate-impact theory, but this rule does not make that link, and your Section 1557 and state-law duties are unchanged. What genuinely changes is the theory under which an intent-free statistical-disparity complaint could be brought against a recipient under part 80.

Arkansas AG sues 13 drugmakers + a data firm over 340B — the first time a state goes on OFFENSE under its own 340B shield law, with the state health-center association standing beside him

Arkansas Attorney General Tim Griffin filed suit July 22, 2026 in Polk County Circuit Court against 22 defendants — 13 drug manufacturers and related entities including Pfizer, Bristol Myers Squibb, AstraZeneca, Eli Lilly, Sanofi and Novo Nordisk, plus data-management firm Second Sight Solutions, LLC — alleging violations of Act 1103 of 2021 and the Arkansas Deceptive Trade Practices Act. WHY THIS IS STRUCTURALLY DIFFERENT FROM EVERY OTHER 340B CASE WE TRACK: in Washington, North Dakota, Missouri, West Virginia/Maryland, Vermont and New Mexico, the pattern is a MANUFACTURER SUING A STATE to block a contract-pharmacy law. This is the inverse — a state attorney general enforcing an enacted 340B shield law against manufacturers, in state court, seeking $10,000 per violation with total civil penalties the coverage puts above $1 billion, plus an injunction barring the restrictions. Act 1103 is the strongest possible platform for it: the 8th Circuit upheld the law and the Supreme Court declined to review it. THE ALLEGED MECHANISM IS THE PART FQHC LEADERS SHOULD READ: the state says manufacturers, unable to restrict contract pharmacies directly, pivoted to conditions Act 1103 does not expressly forbid — chiefly REQUIRING COVERED ENTITIES TO HAND OVER CLAIMS OR MEDICAL DATA to receive 340B pricing — and that each manufacturer adopted near-identical restrictions with little variance. That is the same play as the already-tracked Eli Lilly five-day claims-data ultimatum. Community Health Centers of Arkansas CEO Lanita White appeared at the announcement alongside Griffin. HONEST LIMITS: a complaint is an allegation, not a finding; no ruling exists; and the $1B figure is a sought-penalty ceiling, not a recovery. Its value to California is precedential rather than immediate — it tests whether a state 340B shield law is worth anything without an enforcer, which is the open question hanging over AB 1460.

CY2027 Physician Fee Schedule Proposed Rule Lands — CMS Proposes the FQHC PPS Base Rate Rise to $212.91 (+2.5%), Comments Close September 14

CMS published the CY2027 Physician Fee Schedule proposed rule (CMS-1848-P, FR doc 2026-14327) in today's Federal Register — 91 FR 43842–44557, comments close September 14, 2026. The headline FQHC number, verbatim from the rule at 91 FR 43959: "Multiplying the CY 2026 FQHC PPS base rate amount of $207.72 by the proposed CY 2027 FQHC market basket update of 2.5 percent ($207.72 x 1.025) results in a proposed CY 2027 FQHC PPS base rate amount of $212.91." Treat $212.91 as PROVISIONAL, not locked: CMS states it will refresh the market basket and productivity adjustment at the final rule using historical data through Q2 2026, so the final figure will move. The rule also proposes conforming regulatory text (§§405.2463(b)(3), 405.2469(d)) for CAA-2026 §6209(d), which delays the RHC/FQHC in-person visit requirement for mental-health telehealth to an extended date of January 1, 2028 — note the underlying statute (Pub. L. 119-75, Feb 3 2026) already stands; what is new here is the regulatory codification. Two things not to overstate. (1) The proposed DSMT/MNT stand-alone-visit change is an RHC proposal that aligns RHCs UP to existing FQHC treatment — FQHC payment is unchanged, and it should not be framed as an FQHC win; CMS adds that it does "not expect in future rulemaking to propose additional preventive services beyond which are currently paid for in FQHCs," i.e. it considers the FQHC preventive menu complete. (2) The ACCESS Model co-management G-codes G0676/G0677/G0678 never appear in the 716 pages, and neither does "ACCESS Model" — the rule that would naturally have settled FQHC billing eligibility is silent, so FQHC billing eligibility for those codes remains UNCONFIRMED.

8th Circuit Rejects Novartis's Bid to Block Missouri's 340B Contract-Pharmacy Law — Another State Shield Survives a Manufacturer Challenge

On July 1, 2026, the 8th U.S. Circuit Court of Appeals (Novartis Pharmaceuticals Corp. v. Hanaway, No. 25-1619) affirmed the district court's denial of Novartis's preliminary-injunction bid against Missouri's S.B. 751, which requires manufacturers to deliver 340B drugs to all contract pharmacies serving Missouri covered entities. Per the Missouri Hospital Association, the court found Novartis unlikely to prevail on the merits — any extraterritorial effect of the statute was 'negligible and nondiscriminatory toward out-of-state entities' — and rejected Novartis's attempt to revisit its position on federal preemption; the case now returns to the district court for merits proceedings. The Missouri Primary Care Association (the state's FQHC association) intervened alongside MHA to defend the law. The ruling adds another upheld state 340B contract-pharmacy shield to the circuit-by-circuit map FQHC pharmacy directors are tracking, weeks after Washington's law survived a separate challenge in June.

AHA Files En Banc Review Petition After 4th Circuit Blocks WV 340B Contract Pharmacy Law — Decision Expected Mid-May

American Hospital Association filed en banc review petition April 17 after 4th Circuit panel blocked West Virginia's S.B. 325 (which forced manufacturers to ship 340B drugs to contract pharmacies). Combined with the 4th Circuit's April 14 vacatur of Maryland's similar law, drugmakers won two consecutive 4th Circuit rulings. AHA argues panel decision conflicts with 5th and 8th Circuit rulings, citing critical importance of preserving state-level 340B protections. Decision window typically 30 days. Outcome shapes whether other 4th Circuit states (NC, SC, VA) can pass 340B contract pharmacy access laws — and indirectly affects circuit-split posture for likely Supreme Court review.

25 states and D.C. file the first direct challenge to CMS-2454-IFC's medically-frail and related provisions

A coalition of 25 states and the District of Columbia, with California among the co-leads, filed Commonwealth of Massachusetts v. Oz, No. 1:26-cv-12962-RGS, on June 29, 2026. The filing challenged CMS-2454-IFC provisions governing the medically-frail exclusion and related verification and hardship rules. The rule's additional medically-frail criterion asks whether a qualifying condition significantly impairs the ability to comply with community engagement; the complaint disputes that implementation. This filing did not decide the merits, a person's exclusion, or a number of FQHC patients who will lose coverage. A June 29 Federal Register correction replaces 42 C.F.R. §§ 435.557–435.558. The California filing release also described August 31 as a notification deadline, but § 435.561(b)(1) and CMS Table 2 place initial outreach in September, August, or July according to the state's one-, two-, or three-month applicant lookback. The responsible state Medicaid agency controls verification, official notice, and eligibility decisions. FQHC teams should use current federal and state instructions, avoid predicting a result, and keep disability, eligibility, work, income, immigration, and clinical records out of FQHC Talent.

Los Angeles County certified Measure ER as passed, 50.64% to 49.36% — the general sales tax still requires a county spending plan

The Los Angeles County Registrar-Recorder/County Clerk certified the June 2, 2026 election on June 26. The official result for County Measure ER was 1,013,747 Yes votes (50.64%) and 987,977 No votes (49.36%), satisfying the majority-vote requirement. The official ballot statement describes a temporary 0.5% general sales tax for five years, projected to generate approximately $1 billion annually, with independent audits. Because it is a general tax, passage does not itself award a particular amount to an FQHC, hospital, program, or position; the County must adopt a spending plan and any provider payment or contract must be separately documented. Executives and finance leaders should follow Board actions, adopted allocations, eligibility rules, and executed agreements before recognizing revenue or committing spend. Talent leaders should not open a requisition from the election result, and candidates should wait for an employer-posted vacancy. The prior polling and pre-election advocacy window are retired. Do not put voter, employee-advocacy, patient, or candidate information in FQHC Talent; retain only public results and aggregate planning context.

Senate HELP Chair Cassidy Releases Comprehensive 340B Reform Discussion Draft — the Federal Rewrite Vehicle Arrives

Senate HELP Committee Chair Bill Cassidy (R-LA) released a legislative discussion draft of the '340B Drug Pricing Integrity and Affordability for Patients Act' on June 25, 2026 — the most comprehensive federal 340B rewrite vehicle to emerge this cycle. Key provisions per the committee release and STAT coverage: restrictions on hospital 'child sites' (which would need to provide services beyond drug dispensing and be located in shortage areas) and a requirement that hospital covered entities adopt sliding fee scales — a discipline FQHCs already live under by statute. For health centers, the draft lands in a crowded field: the health-center-side '340C' proposal (a voluntary, transparent subset with contract-pharmacy protection and WAC reimbursement for Medicaid drugs) and the already-tracked bipartisan H.R. 7391 340B FQHC Protection Act remain the CHC counter-positions. Strategic read: most of Cassidy's draft targets hospital behavior, not health centers — but any comprehensive 340B rewrite that moves opens the whole program, contract-pharmacy rules included, while the December 31 CHC Fund cliff still has no legislative vehicle of its own. Status: discussion draft (not yet introduced); comment and stakeholder engagement expected over summer 2026.

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 CMS-2454-IFC taking effect July 31 and full implementation due January 1, 2027, the state map has taken shape. Correction verified August 2 against the printed DATES section at 91 FR 33348: comments were also due July 31, 2026; an earlier update incorrectly said the Federal Register published only an effective date and no comment deadline. 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. A separate 2028 boundary: Oregon guidance restates Section 71120's exclusion for specified community-clinic services; it does not create a current or universal visit exemption or support patient, demand, reimbursement, revenue, staffing, or financial outcome forecasts. 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.

Final California Primary Results Put Xavier Becerra and Steve Hilton in the November 3 Governor Runoff

California's final official Statement of Vote resolves the uncertainty recorded in the original June 5 item. Xavier Becerra finished first with 2,591,857 votes (28.0%), and Steve Hilton finished second with 2,277,318 votes (24.6%); under California's top-two system, they advance to the November 3 general election. Tom Steyer did not advance. For FQHC planning, this is an election-landscape signal rather than immediate operating relief: the next governor takes office after the December 31, 2026 federal health-center funding deadline and the January 1, 2027 start of major Medi-Cal eligibility changes.

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

Historical standoff record: as of June 4 — with the June 15 constitutional budget deadline 11 days out — Governor Newsom and the Assembly (who wanted to renew the long-standing Managed Care Organization tax, ~$4.5B/year) were deadlocked with the state Senate, which instead proposed 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. Signed-budget update: the June 29 budget renewed the MCO-tax path and moved the major UIS/PPS clinic-payment cut into a July 1, 2027 planning horizon, so the live CFO risk is 2027 sensitivity plus January 2027 Medicaid work requirements rather than a July 2026 PPS hit.

CMS issues the community-engagement rule for certain Medicaid adults — effective July 31, with general state implementation by January 1, 2027

On June 1, 2026, CMS issued CMS-2454-IFC to implement the statutory Medicaid community-engagement requirement. It applies to 'applicable individuals'—certain nonpregnant adults ages 19–64 in the Medicaid adult group or certain Section 1115 demonstrations—not every expansion adult or Medicaid member. Exclusions, deemed-compliance paths, and optional short-term-hardship exceptions apply. An affected person can satisfy a month through qualifying work, a work program, community service, half-time education, a qualifying combination, or earnings of at least 80 times the federal hourly minimum wage ($580 in 2026). The rule became effective July 31, 2026, and states generally must implement by January 1, 2027 unless they elect an earlier date. The responsible state agency identifies affected people, verifies compliance or an exclusion, and provides outreach and notice. FQHC teams should use the current official state schedule and the member's exact notice, never infer person-level applicability or a center-level coverage-loss count, and keep eligibility, work, income, disability, immigration, and clinical records out of FQHC Talent.

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

CMS issued CMS-2454-IFC on June 1, 2026, and the Federal Register published it June 3. The rule became effective July 31. Under 42 C.F.R. § 435.561(b)(1) and CMS Table 2, initial outreach for January 1 implementation begins in September, August, or July according to a state's one-, two-, or three-month applicant lookback; there is no single nationwide August outreach deadline. A June 29 Federal Register correction replaces §§ 435.557–435.558, so verification and noncompliance workflows must use the corrected text. The $200 million Government Efficiency Grant program supports state implementation; it is not a direct FQHC navigation grant. FQHC teams should confirm their own state's schedule, work from official notices and approved systems rather than a general timeline, and keep person-level eligibility records out of FQHC Talent.

CMS community-engagement rule is effective, with a June 29 correction and state-specific outreach schedules

CMS issued CMS-2454-IFC on June 1, 2026; the Federal Register published it June 3, and it became effective July 31. The requirement applies to 'applicable individuals'—not every expansion adult or Medicaid member—and exclusions, deemed-compliance paths, and optional short-term-hardship exceptions apply. Under 42 C.F.R. § 435.561(b)(1) and CMS Table 2, initial outreach for January 1 implementation begins in September, August, or July according to a state's one-, two-, or three-month applicant lookback; there is no single nationwide outreach date. A June 29 Federal Register correction replaces §§ 435.557–435.558, so the responsible state Medicaid agency must use the corrected verification and noncompliance text, identify affected people, and control official notice and eligibility decisions. FQHC teams should verify the current state schedule, use the member's exact official notice and authorized systems, avoid any person- or center-level coverage-loss inference, and keep eligibility, work, income, disability, immigration, and clinical records out of FQHC Talent.

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

⚠️ UPDATE (Aug 18, 2026) — THREE OF THE FOUR ARE DEAD. At the Aug 13 suspense hearing AB 2208, AB 2201 and SB 1202 were all held in committee; only AB 2161 survived (as amended). Verified against the Senate Appropriations Committee's own August 13 suspense-results sheet and each bill's leginfo history. There is no revival path — the fiscal deadline was Aug 14 and these are second-year bills of the 2025-26 session. The practical consequence for health centers: AB 2208 would have restored the 3-month retroactive Medi-Cal coverage window H.R. 1 cut to one month for expansion adults, and that state backstop no longer exists. Original May reporting follows. 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.

CMS Proposes Medicare-Based Caps on Medicaid State-Directed Payments (CMS-2449-P) — Comments Close July 21

CMS's proposed rule on Medicaid managed-care state-directed payments and fee-for-service targeted Medicaid practitioner payments (CMS-2449-P, published in the Federal Register May 22, 2026; FR doc 2026-10292) implements Section 71116 of H.R. 1, proposing to cap total payment rates for targeted services at 100% of the published Medicare rate in expansion states and 110% in non-expansion states. Compliance would begin January 1, 2029, with grandfathered state-directed payments phasing down 10 percentage points a year starting January 1, 2028; CMS projects roughly $775 billion in total savings over ten years (~$510B federal). The Association of Clinicians for the Underserved flags the stakes for safety-net providers, noting Medicaid payment 'is already often below the cost of providing care.' Comments are due July 21, 2026 (docket CMS-2026-1916) — the near-term action item for state PCAs and health-center advocates in states that use directed payments to lift Medicaid rates.

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.

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 at CMS — ECM/Community Supports Funding on the 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 — negotiations are expected to run through most of 2026, with a decision anticipated near the December 31 expiration. Without renewal, the Enhanced Care Management (ECM), Community Supports, and CalAIM transformation funding stream 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.