Lobbying & Advocacy

CMS Keeps the 35% Essential Community Provider Standard in the 2027 Marketplace Final Rule — a Rulemaking Win NACHC Fought For

In the 2027 Notice of Benefit and Payment Parameters final rule (published May 15, 2026; effective July 20), HHS declined to finalize its proposal to cut the Essential Community Provider contracting standard from 35% to 20% — qualified health plans must still contract with at least 35% of available ECPs, a category that includes FQHCs, in each service area. NACHC had formally opposed the cut in comments, calling it 'premature' absent any assessment of how the 35% threshold affects access for the low-income patients health centers serve, and claimed the outcome as a rulemaking win in a July 8 post. The final rule also prohibits issuers from including routine non-pediatric (adult) dental services as an essential health benefit and tightens enforcement when premium-tax-credit recipients fail to file and reconcile. For health centers, the standing 35% floor preserves in-network eligibility with Marketplace plans and the commercially insured volume that supports their payer mix.

California's Health-Ballot Deal Withdraws the Executive-Pay Cap and Union-Spending Countermeasure; Proposition 44 Remains

Correction (July 15, 2026): the anticipated three-measure ballot war did not persist past the June 25 withdrawal deadline. California's official withdrawn-measures registry records the $450,000 health-executive compensation cap (#25-0009A1) and the hospital-backed restriction on health-care union political spending (#25-0021A1) as withdrawn June 25, 2026. The separately qualified 90%-of-revenue community-health-clinic spending mandate is now Proposition 44 and remains the direct November 3 risk for nonprofit FQHCs. Planning should therefore focus on Proposition 44's compliance, litigation, and voter-outreach scenarios—not on the two withdrawn countervailing measures.

California Hospital Association Warns FQHC Closures Will Drive Up ED Visits — First Time Hospital Lobby Publicly Backs FQHC Sustainability

California Hospital Association VP of Policy Sheree Lowe publicly warned that FQHC closures will drive up emergency department visits and emergency-response strain, citing UCSF Fresno 2019 research showing FQHC geographic density is linked to a 26-35% drop in ED use among uninsured patients. ≥1,500 FQHCs nationwide are in financial hardship per the article. This is a notable strategic shift: the first time the hospital lobby is publicly making the 'save FQHCs or your EDs drown' argument — a natural-ally narrative FQHC executives can leverage in hospital-FQHC contracting, county budget asks, and Sacramento advocacy. Pairs with KFF rural Medicaid analysis and Geiger Gibson cross-subsidy research already tracked. Strategic implication for FQHC CEOs negotiating with Dignity, Sutter, Adventist, and Kaiser on referral and uncompensated-care arrangements: the lobbying frame just changed.

SEIU-UHW 90% Patient-Care Mandate QUALIFIES for Nov 3, 2026 California Ballot — Existential FQHC Governance Fight Now Confirmed

California Secretary of State Shirley Weber announced on May 19, 2026 that SEIU-UHW's 'Clinic Funding Accountability and Transparency Act' (Initiative #25-0008) has officially qualified for the November 3, 2026 statewide ballot — signature verification certified ahead of the projected June 25 deadline. The measure requires all CA nonprofit FQHCs and Look-Alikes to spend ≥90% of total revenue on direct patient care, clinical staff, and front-line services, with CDPH levying penalties equal to the shortfall. Affects all 213 FQHCs in our directory. This supersedes the prior 'signatures submitted' status and the CPCA + Open Door federal preemption lawsuit (April 30) plus the CHA-led clinic-employer state suit (May 4) did NOT prevent qualification — both lawsuits continue but the ballot fight is now confirmed for November. Strategic implication for FQHC CEOs and boards: (1) Compute current spending ratio under the measure's definition (direct patient care + clinical staff + front-line vs. total revenue) — most FQHCs are within range but margin-sensitive; (2) Brief board on the 5.5-month campaign window through Nov 3; (3) Engage CPCA's 'No on 25-0008' campaign infrastructure and parallel federal/state lawsuit timelines; (4) Develop 90% compliance scenario plans (admin/exec compensation, IT, facilities lines re-classification) as risk-mitigation in case the measure passes; (5) Coordinate patient/community messaging — voters will hear union framing first.

CalChamber 'Affordable California' Files Nearly 1 Million Signatures for November 2026 Ballot — Counter to SEIU-UHW 90% Spend Initiative

CalChamber-led business coalition submitted nearly 1 million signatures April 27 for the 'Affordable California' ballot initiative — a direct counter-pressure measure against SEIU-UHW's 90% patient-care spending mandate (the FQHC accountability initiative that already filed 1.4M signatures April 3). If both qualify, voters will see competing healthcare cost initiatives on the same November 2026 ballot — splitting voter attention and potentially blocking each other. CalChamber framing: SEIU-UHW initiative would 'force closures and reduce access.' SEIU-UHW framing: corporate clinics divert too much revenue from patient care. Signature verification deadline June 25, 2026.

HRSA 340B Rebate Pilot — Both Comment Windows Closed; AHA, ASHP, NACHC, WHA All Filed Formal Opposition

Both HRSA 340B Rebate Model comment windows are now closed: the main RFI deadline (April 20) and the burden-focused ICR deadline (April 27). AHA, ASHP, NACHC, and WHA all filed formal opposition arguing the rebate model — converting upfront 340B discounts into back-end rebates — would cost FQHCs and hospitals over $1B/year, jeopardize access, and force compliance burden benefiting Second Sight Solutions (the third-party vendor) and drug manufacturers. Pilot would cover up to 25 drugs from 13 manufacturers with Medicare Drug Price Negotiation Program agreements. Decision now rests with HHS following the Maine District Court vacating the original notice in February 2026. Industry-wide opposition is the strongest unified safety-net front in 340B's 30-year history.

AHA Files Formal Opposition to HRSA 340B Rebate Model — FQHC/Hospital Alignment on 'Flawed Mechanism'

The American Hospital Association filed formal opposition to HRSA's 340B rebate model RFI on April 20, 2026 — the comment deadline — framing 'any rebate mechanism is flawed' and warning the shift will cost billions and jeopardize access for millions. AHA joins NACHC and PhRMA in opposing the rebate pilot. The unified FQHC/hospital front strengthens the 340B defense as manufacturer rebate plans continue activating (Lilly, Novo already live; 9th plan effective April 1).

Health4All Coalition Mobilizes Defense of UIS Adult Dental Benefit + $30 Premium Reversal — Distinct From SB 1422

Historical campaign record: Health Access California (chair), California Immigrant Policy Center, Latino Coalition for a Healthy California, CPEHN, and Western Center for Law on Poverty mobilized a separate Health4All Coalition campaign distinct from SB 1422. Two policy levers were active in the May Revise window: (1) reversing the then-proposed July 1, 2026 elimination of adult dental benefits for UIS Medi-Cal patients, and (2) blocking the mandatory $30/month premium for UIS adults ages 19-59 starting July 2027. Signed-budget outcome: the June 29 budget delayed the UIS adult dental cut to July 1, 2027, so this item is advocacy context for the next budget cycle rather than live July 2026 guidance.

NACHC Activates National In-District Advocacy Week April 14–25 — FQHCs Hosting Congress During Recess

NACHC is mobilizing health centers nationally to host members of Congress in their clinics April 14–25 — the last major advocacy window before the Senate reconciliation vote on Medicaid cuts. CPCA is coordinating California in-district visits. The window is open right now.

CCALAC + Coalition of OC Community Health Centers Convene Joint Vision Summit — SoCal FQHC Alliance

The Community Clinic Association of Los Angeles County (CCALAC) and the Coalition of Orange County Community Health Centers held a joint convening April 10, 2026 to align on a shared Southern California FQHC vision centered on dignity-based care and collective policy advocacy amid federal Medicaid cuts. The unprecedented LA+OC coalition signals the sector is consolidating voice to counter H.R. 1, the SEIU-UHW ballot initiative, and state-level budget pressures.

CCALAC & Coalition OC Unite at 25th Annual SoCal Symposium: 'Dangerous Policies' Threaten Safety Net

The Community Clinic Association of LA County (CCALAC) and the Coalition of Orange County Community Health Centers co-hosted the 25th Annual Southern California Health Care Symposium on April 10, naming 'dangerous state and federal policies coupled with a worsening workforce crisis' as threats to safety-net capacity. The event represents unified SoCal advocacy across LA + OC (100+ FQHCs) heading into the June 2 sales tax ballot and legislative session.

NACHC Report: 55% of Community Health Centers Cannot Fill Critical Positions

NACHC's latest workforce report finds 55% of community health centers face critical staffing shortages. Vacancy rates exceed 20% for physicians, nurses, and behavioral health providers. Meanwhile, 5.6 million patients could lose coverage under proposed work requirements — a $32 billion revenue loss for the CHC sector nationally.

NACHC P&I Forum: $4.6B CHCF Funding — Largest Increase in a Decade, But Expires Dec 2026

At the NACHC Policy & Issues Forum (Feb 9-12), leaders celebrated the $4.6B Community Health Center Fund as the largest increase in a decade, but warned it expires December 31, 2026 without reauthorization. NACHC also released policy papers on 340B drug pricing protection, workforce pipeline, telehealth permanence, and Medicare FFS reform. The program posted a 2% patient loss in 2025.

HRSA FY2026 Grants Aligned with 'Make America Healthy Again' Priorities

HRSA's FY2026 health center grants are being aligned with the administration's 'Make America Healthy Again' (MAHA) initiative, shifting funding priorities toward chronic disease prevention, nutrition, and mental health. FQHCs applying for new grants or renewals should align proposals with these priorities to maximize competitiveness.

LA County Healthcare Coalition Proposes Half-Cent Sales Tax to Replace Federal Cuts

A coalition led by St. John's Community Health CEO Jim Mangia, SEIU locals 721 and 2015, Community Clinic Association of LA County, and Planned Parenthood is pushing for a half-cent sales tax to offset Medi-Cal cuts affecting 3.3M county residents. Proposed allocation: 47% free/reduced-cost care for uninsured, 22% DHS, 10% DPH. Coalition requesting Board of Supervisors place measure on June ballot or will pursue November initiative through petition.

NACHC: $630M Could Hire 1,070 Optometrists at FQHCs to Serve 10.7M Unserved Patients — Only 26% of CHCs Currently Offer Vision

NACHC 2025 Vision Services Expansion Brief documents the structural underbuild: only 26% of US Community Health Centers offered vision services in 2023, and just 3% of CHC patients received eye care annually. NACHC estimates a one-time $630M investment could hire 1,070 optometrists serving 10.7 million currently unserved patients. Vision is among the most profitable FQHC service lines (PPS-encounter eligible) yet 3 of 4 FQHCs leave it on the table. Two structural barriers: (1) optometry is NOT eligible for NHSC Loan Repayment, (2) vision is non-mandatory under HRSA Section 330 — base grants cannot launch new vision lines, must come from expansion grants, 340B savings, or operating capital.