Lobbying & Advocacy in Federal

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.

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).

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.

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.

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.