Tracking legislation, ballot initiatives, coalition actions, and legal rulings protecting FQHC funding. Follow-up dates, outcomes, and tools to take action.
Sep 7, 2026(16 days)— Re-check the official ILGA status pages for posted Public Act numbers and implementation materials; monitor Illinois Department of Insurance study guidance and any manufacturer challenge to the contract-pharmacy protections. Do not infer a Public Act number or litigation outcome before an official source posts it.
Both bills were signed August 7. HB 2371's contract-pharmacy protections and HB 4327's linked transparency-study framework moved from pending legislation to enacted law; Public Act numbers were not yet verified on the official status pages.
Sep 15, 2026(24 days)— Check whether Ways and Means and Education and Workforce have resolved jurisdictional language and whether a House floor vote has been scheduled. Also check for any Senate companion introduction, which as of July 27 was not reported.
Nov 1, 2026(71 days)— Check whether the CY2027 Physician Fee Schedule final rule addresses the telehealth payment methodology for health centers and rural health clinics. Note that the comment deadline for the CY2027 proposed rule was NOT verified from primary Federal Register text in this run, so confirm it before relying on any date.
Nov 3, 2026(73 days)— Watch whether other regional chambers or general business groups follow. A health-sector-only opposition is easy for proponents to frame as self-interested; business-community opposition changes that framing. Election day is November 3, 2026.
Sep 30, 2026(39 days)— Check for any committee referral or markup activity; as a minority-sponsored omnibus, expect no near-term floor action. Watch whether specific HEAA workforce / community-health-worker provisions get pulled into other 2026-2027 legislative vehicles.
Sep 15, 2026(24 days)— Watch for defendants' responsive pleadings (removal to federal court is the obvious first move) and any preliminary ruling on the Deceptive Trade Practices Act theory. The question this case answers for California: is a state 340B shield law worth anything without an attorney general willing to enforce it? That is the open question behind AB 1460, which remains pending in Senate Health with no confirmed 2026 hearing date.
Sep 30, 2026(39 days)— Watch for a manufacturer petition for en banc rehearing or Supreme Court review, and any HHS move to authorize its own rebate pilot.
Nov 3, 2026(73 days)— Election is November 3, 2026. The coalition-growth question answered itself on Aug 2: the California Democratic Party formally joined the No on 44 coalition — the first major-party endorsement on either side, and a materially bigger name than anything in the founding roster. With CPCA v. Weber decided Aug 7 on standing (Prop 44 stays on the ballot), the fight now runs entirely through the campaign. Interim: watch Cal-Access committee filings for funding totals on both sides.
CMS retained the 35% ECP contracting requirement in the 2027 NBPP final rule (published May 15, 2026; effective July 20) — a favorable outcome protecting health-center participation in Marketplace plan networks.
Sep 1, 2026(10 days)— Watch for committee action/markup and whether H.R. 9599 converges with or competes against Sen. Cassidy's 340B discussion draft; how the 24-month statutory patient definition treats health-center operations is the key question for FQHCs.
Oct 1, 2026(40 days)— UPDATE (July 30): per McDermott's 'This Week in 340B' (July 14–20 edition), Novartis has petitioned for REHEARING EN BANC of the 8th Circuit's July 1 affirmance, and at the district court an amended motion to dismiss plus cross summary-judgment motions are pending — the ruling stands but is not final. Watch the en banc decision and the district-court merits proceedings, and whether other circuits diverge (the manufacturer challenges to state contract-pharmacy laws continue circuit by circuit — Oregon's cross-motions are now fully briefed).
Favorable to covered entities: the 8th Circuit affirmed denial of Novartis's preliminary injunction, leaving Missouri's S.B. 751 contract-pharmacy protections in force while the merits proceed.
Sep 15, 2026(24 days)— RULING (July 29): Judge Stearns DENIED the preliminary injunction one day after the July 28 hearing. The denial rested on failure to show irreparable harm, was issued WITHOUT PREJUDICE, and left CMS-2454-IFC effective July 31. Correction verified August 2: 42 CFR 435.561(b)(1) and CMS Table 2 do not create a universal August 31 member-notification deadline; initial outreach begins in July, August, or September according to the state's selected applicant lookback. Next check: the merits briefing schedule (~September), each plaintiff state's verified outreach month, and any new state guidance.
Nov 3, 2026(73 days)— November 3, 2026. If Prop 40 and either countermeasure both pass, the higher vote total prevails — track relative polling, not just Prop 40's own margin. UPDATE (Aug 20): the California Democratic Party endorsed Prop 40 on Aug 2 — on a second attempt, 145-90 (about 61.7%, just over the 60% threshold) — putting the state party on the opposite side from Gov. Newsom, business groups, and some of its own labor allies; SEIU California remains neutral and Sergey Brin's $82M opposition spend stands. The intra-Democratic split now runs party-vs-governor, which cuts both ways for turnout and messaging.
Sep 1, 2026(10 days)— Watch for formal introduction and whether the health-center '340C' carve-out gains traction as the draft advances through summer 2026.
Nov 3, 2026(73 days)— November 3, 2026 — the 90% clinic-spending mandate (Measure 1986) goes to voters. Track the CPCA / Open Door federal preemption suit (N.D. Cal.) for any pre-election ruling, plus campaign spending and polling on Measure 1986.
June 25, 2026: Measure 1985 ($450K hospital-exec-pay cap) and the CHA union-political-spending measure (#25-0021) were withdrawn by mutual deal; Measure 1986 (90% clinic-spending mandate) and the 5% billionaire-wealth-tax measure remain on the November 3 ballot.
Nov 3, 2026(73 days)— RESOLVED at the June 25 deadline: NO deal on the billionaire tax. Newsom rejected the union's 2% legislative alternative, no 2% bill was enacted, and the union did NOT withdraw — so the 5% wealth tax IS on the November 3, 2026 ballot (one of 14 statewide measures). The separate June 24 SEIU-UHW/CHA mutual-disarmament deal withdrew only the exec-pay cap (#25-0009) and CHA's counter-measure (#25-0021); it did NOT touch this measure or the #25-0008 90% clinic-spending measure. UPDATE (July 13): the Secretary of State has assigned official numbers — this measure is PROPOSITION 40; the 90% clinic-spending measure is PROPOSITION 44. Next milestone: the November 3 vote.
On the November 3, 2026 ballot — no withdrawal deal reached by the June 25 deadline.
Nov 3, 2026(73 days)— November 3, 2026 general election — Becerra vs. the second-place finisher. Track whether a Becerra win materially changes the post-cliff Medi-Cal/FQHC funding posture for the January 2027 transition.
Nov 3, 2026(73 days)— November 3, 2026 election — Measure 1986 remains on the statewide ballot; watch campaign spending, court challenges, and voter-guide arguments.
June 25 withdrawal deadline passed; the Secretary of State's qualified-measures list includes Measure 1986 but not the CHA union-spending countermeasure.
FAILED ~42.1% yes / ~57.9% no (June 5 count) — no local backstop for Contra Costa Health as H.R. 1 lands and signed-budget UIS/PPS risk moves into a July 1, 2027 planning horizon.
Sep 30, 2026(39 days)— FY2027 discretionary funding also expires Sept 30; a CHCF/NHSC extension is most likely to ride a year-end CR or reconciliation vehicle — track for an introduced bill.
Jun 1, 2027(283 days)— Application deadline July 15, 2026 at 3:00 PM — FQHCs should apply for BH recruitment/retention/supervision awards
The 2026 application cycle closed July 15, 2026 at 3:00 p.m., having opened June 1, 2026. HCAI's program page now reads "2026 Application Cycle: CLOSED" and directs applicants to check back for information on the next application cycle in March 2027; no award-announcement date has been published for the 2026 cohort. FQHCs are named directly in the program's eligibility requirements as an eligible organization type. Verified against hcai.ca.gov on July 31, 2026.
Sep 12, 2026(21 days)— Status check (July 16): the June 24 Senate Health meeting came and went with AB 1460 never appearing on a published agenda — vindicating the June 20 softening. A re-check of leginfo shows NO legislative activity on AB 1460 in the entire 2026 session; the last scheduled hearing remains the postponed July 16, 2025 date. Honest read: a two-year bill with zero 2026 movement heading into recess is LIKELY DEAD for the session — frame it that way rather than implying an imminent hearing. Sept 12 is the deadline to pass bills to the Governor and is the next real checkpoint; if nothing moves by then, the item should be closed out. Washington's SB 5981 surviving its June 9 injunction challenge remains the strongest fresh precedent that a well-drafted state 340B law can hold; CCAGW has filed formal opposition.
Aug 31, 2026(9 days)— SURVIVED SUSPENSE Aug 13 (13-0) — verified on leginfo. Rule 63 was suspended and the bill was placed on the Assembly Third Reading File for Aug 18-19. It now needs an Assembly floor vote before the Aug 31 adjournment, then the Governor's Sept 30 sign-or-veto deadline. For FQHCs running behavioral-health integration this stays a live compliance trigger on any AI used in BH care. | PRIOR NOTE: Status update (Aug 6, CalMatters): SB 903 has cleared Assembly Health and is now awaiting a vote in Assembly Appropriations — no floor-vote date yet, still active. Aligning the follow-up with the Aug 13-14 legislative suspense-file window (the same fiscal chokepoint deciding the CA H.R.1-mitigation package).
Sep 30, 2026(39 days)— RESOLVED Aug 13 — three of the four died. Verified today (Aug 18) against the Senate Appropriations Committee's own "Suspense File Hearing - Unofficial Results, August 13, 2026" sheet and each bill's leginfo history. AB 2208 (Stefani) — "Hold in committee"; leginfo shows "08/13/26 In committee: Held under submission." AB 2201 (Boerner) — "Hold in committee," same leginfo language. SB 1202 (Weber-Pierson), the outlier in ASSEMBLY Appropriations — "Held in committee and under submission" on 08/13/26. Only AB 2161 (Bonta) survived, "Do Pass as Amended," and was ordered to third reading Aug 17; AB 2756 (Ahrens, Medi-Cal vision quality reporting) also cleared, "Do Pass." There is no revival path: the fiscal-committee deadline was Aug 14, Aug 17-31 is floor session only, and as second-year bills of the 2025-26 session they die with it. Next check is the Governor's Sept 30 sign-or-veto deadline for AB 2161 and AB 2756. CAUTION on AB 2161: it survived AS AMENDED at suspense, and suspense amendments routinely narrow scope — read the amended text before restating what it does. UPDATE (Aug 20): AB 2161 was amended AGAIN on the Senate floor Aug 19 ('Read third time and amended,' ordered back to second reading), so there are now TWO amended texts past the suspense version. The Aug-19 amendments add procedural-disenrollment guardrails: counties must maintain active eligibility pending work-requirement verification until at least the last day of the month, notices must go out by mail, email, text, and phone, and the department must consider all other bases of Medi-Cal eligibility before any denial — the provisions that decide how many patients health centers lose to paperwork when the federal requirement starts Jan 1, 2027. It still needs a Senate floor vote plus Assembly concurrence by Aug 31. AB 2756 was ordered to the Senate special consent calendar Aug 18 — an uncontested floor vote is imminent.
Three of the four mitigation bills were held on the suspense file and are dead for the 2025-26 session: AB 2208 (cost-sharing cap + restoration of the 3-month retroactive Medi-Cal coverage window), AB 2201 (renewal automation), and SB 1202 (public disenrollment dashboard). AB 2161 survived as amended. The loss that matters most to health-center finance is AB 2208: retroactive coverage is what lets a center bill for care delivered before a patient's eligibility is finalized, and H.R. 1 cuts that window to one month for expansion adults. California FQHCs now have no state backstop against that change. Worth noting for how to read this: AB 2201 had cleared Senate Health 10-0 to the consent calendar — a consensus bill that died purely on cost, which says more about the FY26-27 fiscal environment than about opposition to the policy.
AB 403 (Ortega) died January 31, 2026 under the two-year-bill deadline in Cal. Const. Art. IV, Sec. 10(c), with Assembly Appropriations as its location of record — it never advanced to the Senate. It therefore created no July 1, 2027 DHCS CHW/Promotora reporting requirement, and no statutory annual CHW utilization reporting mandate exists in its place. DHCS continues to publish CHW utilization data only through non-statutory channels such as its dashboards and ECM/Community Supports quarterly implementation reports.
The budget window this rally targeted has closed: the Legislature reached a two-chamber agreement June 11, passed the budget June 13, and the Governor signed it June 29, 2026. The result was mixed — the State-Only/UIS clinic-payment (PPS) reduction and the UIS adult dental cut were delayed twelve months to July 1, 2027, but the package still moves roughly 2 million UIS Medi-Cal enrollees from managed care to fee-for-service on January 1, 2027 (a ~$470M/year state saving that ends case management, housing assistance, and medically tailored meals for that population), limits ~150,000 humanitarian immigrants to emergency and pregnancy care from July 2027, and excluded the Legislature's $125M county indigent-care request. We assert no causal link between the rally and the budget outcome. Note that SEIU 1021's bargaining unit here is Alameda Health System county-hospital staff, not FQHC employees; reading hospital-directed budget lines as relevant to these workers is our inference, and no AHS-specific award is documented.
Sep 30, 2026(39 days)— Fly-In concluded — the live question is now CHC Fund reauthorization beyond the Dec 31, 2026 cliff; watch FY2027 appropriations (discretionary CHC funding lapses Sept 30) for any multi-year extension
The June 2-3, 2026 Fly-In took place as scheduled — CA and national CHC advocates held hundreds of congressional meetings pressing for CHC Fund reauthorization. The ~$4.6B Community Health Center Fund was funded for FY2026 via the Consolidated Appropriations Act, 2026 (NACHC called it the largest mandatory CHC Fund increase in a decade), but a multi-year reauthorization beyond the December 31, 2026 cliff remains UNENACTED — the fight has shifted to FY2027 appropriations.
Jan 10, 2027(141 days)— Budget conference committee window — track county legal/political response
Partially resolved against counties on the indigent-care line specifically: the enacted FY2026-27 budget delivered $0 for county indigent care — CSAC's Graham Knaus, post-enactment: "There is zero in the state budget related to indigent care." CSAC and allied county groups had sought $50M for FY2026-27 and $462M for FY2027-28 for indigent care, and both were denied for the current year; counties and the broader community health system were not shut out entirely, since the same budget provides $250M for public hospitals and $420M for benefits-enrollment staffing. Read this as a targeted denial of the indigent-care backfill rather than a rejection of the full $6.4B two-year community health demand this item tracks — those are different asks with different scopes and should not be reconciled into one number — and note that no county litigation over budget elements has surfaced in our sources (absence of evidence, not evidence of absence). The FY2027-28 half of the demand remains undecided and carries into the next budget cycle, which opens when the Governor submits the FY2027-28 budget by the January 10 constitutional deadline.
Jan 10, 2027(141 days)— Budget conference committee window — track final May Revise + Senate/Assembly counter
The coalition won a twelve-month delay, not a defeat of the cuts: the Governor signed the 2026-27 budget on June 29, 2026, and the final agreement pushed the most harmful Medi-Cal cuts for immigrant Californians to July 1, 2027, so roughly 200,000 lawfully present immigrants with humanitarian status — refugees, asylees, humanitarian parolees, and survivors of domestic violence or trafficking with pending cases — keep full-scope Medi-Cal until then, after which they are limited to emergency and pregnancy-related services. The honest limits: this same population begins losing FEDERAL benefits on October 1, 2026 under H.R. 1, so the state action is a state-funded bridge rather than full protection; monthly premiums still rise to $50 for certain immigrants ages 19-59; roughly 2 million enrollees shift to fee-for-service Medi-Cal on January 1, 2027; and while the Governor's proposed $2,000/$3,000 asset limits were rejected, a lower asset limit relative to the current $130,000/$195,000 was deferred to July 1, 2027 rather than dropped. This is a runway into the next budget fight under an incoming governor, not a permanent block — and none of the source reporting names FQHCs or Section 330 health centers, so the health-center revenue and panel impact is our inference from the coverage change. Sourcing correction: the Governor's signing release does not contain these provisions, so this entry should cite the National Health Law Program, Health Access, or California Immigrant Policy Center final-budget summaries instead, and the previously carried 1.6M and 150,000 figures are dropped as unsourced.
Sep 30, 2026(39 days)— In-district window and the June 2-3 DC Fly-In are done — watch FY2027 appropriations and any CHC Fund extension ahead of the Dec 31, 2026 mandatory-funding cliff
The May 24–June 1 in-district lobby window closed and was followed by NACHC's June 2-3 Washington DC Fly-In. No 2026 reconciliation cuts to health centers advanced — Senate Finance received no reconciliation instructions — but CHC Fund reauthorization beyond the December 31, 2026 cliff is still unresolved.
May 11, 2027(262 days)— Comment period closes July 6 — CCALAC/CPCA should submit FQHC-specific comments shaping final rule
The interim final rule (FR 2026-09266, RIN 0945-AA30) published May 11, 2026 and took effect May 7, 2026, so the one-year extension is in force and compliance deadlines are now May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for those with fewer. Verified against the Federal Register API on July 31, 2026: docket HHS-OCR-2026-0133 and RIN 0945-AA30 each return exactly one document — the IFR itself — so HHS has published no final rule and the IFR remains the operative rule. Correction: the widely circulated "comments close July 6, 2026" is unverified and should not be restated as fact — the DATES section reads only "Effective date: This IFR is effective May 7, 2026" and the API's comments_close_on field is null; it appears to have been computed as a standard 60-day period rather than read from the rule, and comment volume could not be verified because regulations.gov blocks automated access. Operationally, the extended deadlines apply today and do not await further rulemaking, though HHS could still revise them in a subsequent final rule.
Newsom's May 14 May Revision did NOT honor the Assembly's 'line in the sand' — it retained the UIS Medi-Cal enrollment freeze, the July 1, 2026 UIS adult dental elimination, the ~$1B Medi-Cal Dental supplemental-payment cut, and proposed RAISING the UIS premium from $30 to $50/month. The Assembly and Senate kept pushing back, and the budget signed June 29, 2026 LARGELY honored the line. Per the Assembly Budget Committee's June 11 Floor Report, it 'delays most clinic cuts by 12 months' and appropriates $1,034,000,000 General Fund in 2026-27 to maintain clinics' PPS reimbursements for state-only Medi-Cal populations — delaying the ~$1B UIS-PPS health-center cut from July 1, 2026 to July 1, 2027 — and it also delays the UIS adult dental elimination and the Prop 56 Medi-Cal Dental supplemental-rate elimination to July 1, 2027, renews the MCO tax (dropping the Senate's $285/employee fee), and defers the enrollment-freeze pause + $30→$50 premium + $2,000 asset limit to July 2027. The caveat: it is a one-year reprieve, not a permanent repeal (all of it returns July 1, 2027 unless the next budget extends it, and the next governor inherits that).
Nov 3, 2026(73 days)— Signature verification deadline; track which named coalition orgs are also FQHC partners
Qualified: the "Building an Affordable California Act" — CalChamber's CEQA-streamlining initiative — reached the November 3, 2026 ballot in June 2026 as PROPOSITION 45, certified by the Secretary of State as "Modifies environmental review for certain projects. Initiative statute." (sources differ on the exact qualification day — the campaign says June 17, other coverage says June 25 — so we cite the month only). On the FQHC-partner question, the campaign's public coalition roster lists three healthcare organizations: the California Hospital Association, the California Children's Hospital Association, and — named exactly this way — "California Primary Care Association Advocates," the 501(c)(4) advocacy arm of the state health-center association, which is the SAME entity that sponsors the "No On Prop 44" committee, so the health-center sector is aligning measure-by-measure, not bloc-by-bloc. SOURCING CAVEAT: this endorsement appears only on proponent-controlled sources (the Yes on Prop 45 coalition page and CalChamber Alert, both published by the measure's backers) and is not independently corroborated by CPCA Advocates' own publications or by third-party reporting; note also that the endorser is CPCA Advocates, not CPCA itself — do not restate this as the trade association endorsing a ballot measure. Prop 45 is a CEQA measure that names no FQHCs or Section 330 health centers anywhere in its text; the health-center relevance here is our inference from coalition membership, not a claim made by the measure or its sponsor.
Newsom's May 14 May Revision did NOT adopt the coalition's 'Medi-Cal 2030' principles — it maintained the January 2026 UIS enrollment freeze, kept the then-proposed July 1, 2026 UIS adult dental elimination, and proposed raising the UIS premium from $30 to $50/month. The June 29 signed budget later changed the live posture: UIS adult dental and major clinic PPS cuts were delayed to July 1, 2027, making this item historical context for the next budget fight rather than current-law July 2026 guidance.
Jan 10, 2027(141 days)— Signed-budget outcome: the June 29 budget delayed the major UIS/PPS and UIS adult dental cuts to July 1, 2027; use this as coalition context for the 2027 implementation fight.
The May 14, 2026 May Revision kept every proposal the coalition opposed — the UIS Medi-Cal enrollment freeze, the then-proposed July 1, 2026 UIS adult dental elimination, and the State-Only PPS-to-non-PPS reimbursement change. The budget signed June 29, 2026 then delayed both the major UIS/PPS clinic-payment cut and the UIS adult dental elimination to July 1, 2027; per the Assembly Budget Committee's June 11 Floor Report, the $1,034,000,000 General Fund appropriation in 2026-27 is specifically for maintaining clinics' PPS reimbursements for state-only Medi-Cal populations, and the dental delay is a separate budget action not funded out of that line. This is a one-year reprieve, not a repeal — both return July 1, 2027 unless the next budget extends them. The coalition's $125M county indigent-care ask was excluded from the signed budget.
Nov 3, 2026(73 days)— RULING ISSUED Aug 7, 2026 — docket-verified today (Aug 18). CourtListener docket 73277067 shows entry #44 filed Aug 7: "Order on Motion for Preliminary Injunction AND Order on Motion to Dismiss AND Order on Motion to Dismiss AND Order on Motion to Dismiss/Lack of Jurisdiction" (plus entry #45, "Order"), and a text-only Motion Hearing entry confirms the July 31 hearing was held. Per Courthouse News, Magistrate Judge Alex G. Tse resolved it on STANDING, expressly not on the constitutional merits, in a 14-page ruling — and Prop 44 REMAINS ON THE NOVEMBER 3 BALLOT. Sourcing stated honestly: the order documents are PACER-only (not in RECAP), so we have not read the order itself; courthousenews.com 403s to direct fetch, so its account reached us through the search index. Treat the reasoning as well-corroborated but not first-hand, and note the docket carries no case-termination marker. The live watch item is now a post-election challenge if Prop 44 passes — the standing defect the court identified (no defined "qualifying expenditures," no measure yet in force) is exactly what passage would cure. | PRIOR NOTE: UPDATE 2026-07-31: the consolidated federal hearing was set for today and NO ruling, order, or minute entry is docketed as of this check (CourtListener/RECAP, docket 73277067); PACER is unreachable from this environment, so 'no ruling' means 'nothing in RECAP,' not 'the court has not ruled.' Rolled to Aug 21 to track the federal PI decision. The ~June 15 preliminary-injunction window lapsed with no reported state-court ruling; the measure is confirmed on the November ballot (now numbered Prop 44), and the June 25 withdrawal deadline passed. The live fight is entirely on the N.D. Cal. federal preemption track — CPCA v. Weber, 3:26-cv-03837, consolidated PI + motion-to-dismiss hearing July 31, 2026. CORRECTION (docket-verified 2026-07-22): in the FEDERAL case CHA appears as an AMICUS (leave granted June 30, dkts 38/39), not as a co-plaintiff; this entry's May 4 state-court filing is a separate action and the two should not be conflated.
Jan 10, 2027(141 days)— Budget vote deadline; check which FQHC asks made it into final budget
The advocacy window closed with most FQHC asks won for one year: the budget signed June 29, 2026 delays the UIS/State-Only PPS clinic-payment cut, the UIS adult dental elimination, and the Proposition 56 Medi-Cal Dental supplemental-rate elimination all to July 1, 2027, and appropriates $1,010,655 thousand General Fund in 2026-27 — about $1.01 billion, not the widely circulated $1.034 billion, which is the superseded June 11 agreement figure — to support clinics' Prospective Payment System reimbursements for state-only Medi-Cal populations (Assembly Budget Committee Floor Report, June 27, 2026; mechanism is SB 164). Also won: the budget adopts the Administration's MCO tax trailer bill, allocates $15,000,000 for promotora workforce training and expansion, gives counties $196.9 million General Fund for H.R. 1 eligibility workload, and gives public hospitals $250 million; immigrant-coverage asks were partially won, with the UIS premium increase deferred (the 2027-28 May Revision must set it between $30 and $50 per month) and the current $130,000-per-person asset test maintained until July 1, 2027 before dropping to $21,000 per person. Read the whole package as a one-year reprieve, not a repeal — everything returns July 1, 2027 unless the next budget extends it — and note that the budget separately transitions UIS enrollees from Medi-Cal managed care to fee-for-service effective January 1, 2027, removing care-management benefits six months before the rate cliff, with $31 million for care coordination plus $8 million for clinic and community-based-organization navigation contracts. Two caveats: the separate county indigent-care ask does not appear as a funded line in the enacted Floor Report, which we read as it not being funded (our inference, not a stated finding), and whether Proposition 35 rate increases were funded is NOT verified — Prop 35 appears nowhere in the enacted Floor Report and CHA has separately alleged a diversion of Prop 35 funds, so do not cite it as a win until reconciled.
Sep 30, 2026(39 days)— Rebate pilot is vacated/remanded and not operating — watch HRSA's rebate-model RFI process; HRSA committed to at least 90 days' notice before any relaunch
Resolved in FQHCs' favor: the 340B Rebate Model Pilot was vacated and remanded to HRSA (the U.S. District Court for the District of Maine granted the parties' joint motion Feb 10, 2026, after the First Circuit denied the government's stay Jan 8), so upfront 340B discounts remain in place. HRSA reopened a notice-and-comment RFI and committed to at least 90 days' notice before any relaunch — so as of June 2026 no rebate model is operating and the emergency-injunction fight was overtaken by the vacatur.
Nov 3, 2026(73 days)— RULING ISSUED Aug 7, 2026 — docket-verified today (Aug 18). CourtListener docket 73277067 shows entry #44 filed Aug 7: "Order on Motion for Preliminary Injunction AND Order on Motion to Dismiss AND Order on Motion to Dismiss AND Order on Motion to Dismiss/Lack of Jurisdiction" (plus entry #45, "Order"), and a text-only Motion Hearing entry confirms the July 31 hearing was held. Per Courthouse News, Magistrate Judge Alex G. Tse resolved it on STANDING, expressly not on the constitutional merits, in a 14-page ruling — and Prop 44 REMAINS ON THE NOVEMBER 3 BALLOT. Sourcing stated honestly: the order documents are PACER-only (not in RECAP), so we have not read the order itself; courthousenews.com 403s to direct fetch, so its account reached us through the search index. Treat the reasoning as well-corroborated but not first-hand, and note the docket carries no case-termination marker. The live watch item is now a post-election challenge if Prop 44 passes — the standing defect the court identified (no defined "qualifying expenditures," no measure yet in force) is exactly what passage would cure. | PRIOR NOTE: DOCKET RE-VERIFIED 2026-07-31 (CourtListener API, docket 73277067): captioned California Primary Care Association v. Weber, Ph.D., No. 3:26-cv-03837 (N.D. Cal.), before Magistrate Judge Alex G. Tse on full party consent. Filed April 30, 2026. Briefing CLOSED July 10 (entries 40-42). A single consolidated hearing set for TODAY, July 31, 2026 at 10:00 AM (San Francisco) decides BOTH plaintiffs' preliminary-injunction motion and two motions to dismiss — the Secretary of State's (dkt 31/33) and SEIU-UHW's jurisdictional/failure-to-state-a-claim motion (dkt 32/33 amended). Amicus briefs granted to the California Medical Association/Physician Coalition and the California Hospital Association (dkts 34-39, June 18-30) — CHA appears ONLY as an amicus here, never as a party or co-plaintiff, and the docket confirms it. Initial Case Management Conference set September 11, 2026. AS OF 2026-07-31 NO RULING, ORDER, OR MINUTE ENTRY IS DOCKETED, and there is zero press coverage of the hearing; the highest docket entry is 42 and the latest entry date is July 10. Stated honestly: RECAP only mirrors documents a subscriber has purchased and PACER is not reachable from this environment, so we cannot confirm whether the hearing was held, continued, or submitted on the papers — 'no ruling' means 'nothing docketed in RECAP,' not 'the court has not ruled.' Follow-up moved to Aug 21: a fully-briefed PI typically rules days-to-weeks after submission, and the real pressure is the Nov 3 ballot and the Secretary of State's ballot-printing clock. A ruling that keeps Prop 44 on the ballot, or enjoins it, is the single highest-impact FQHC advocacy outcome of Q3.
Sep 12, 2026(21 days)— Watch for a North Dakota appeal to the 8th Circuit + any read-through cited in AB 1460's Senate analysis.
HB 1473 remains struck down and permanently enjoined: on April 27, 2026 the U.S. District Court for the District of North Dakota (Judge Traynor) held the law preempted by federal law and unconstitutional under the Commerce Clause. An appeal is now docketed in the Eighth Circuit — Pharmaceutical Research and Mfrs. v. Drew Wrigley, No. 26-1860, docketed May 5, 2026, with amicus briefs from 340B Health and the American Hospital Association — and the district court denied a motion to stay the judgment pending appeal, so the injunction stays in force and HB 1473 is unenforceable while the appeal runs. We could not verify the date of that stay denial (the Bloomberg Law report is paywalled) and have not read the notice of appeal, so which party filed is unconfirmed; North Dakota is the likely appellant because the state moved for the stay, but treat that as unconfirmed. Neither the district court ruling nor the appeal names FQHCs or Section 330 health centers — the relevance to California's AB 1460 is our inference, not a court finding, and we make no prediction about how the Eighth Circuit will rule.
Nov 3, 2026(73 days)— Signature verification deadline; track whether both this and SEIU-UHW initiative qualify for November ballot
SCOPE CORRECTION to this entry: the CalChamber-sponsored "Building an Affordable California Act" is a CEQA / environmental-review streamlining measure, not a healthcare-cost counter-measure to the SEIU-UHW initiative. It is now PROPOSITION 45, "Modifies environmental review for certain projects. Initiative statute.", certified by the Secretary of State on June 25, 2026 (CalChamber announced qualification June 17); the SEIU-UHW clinic-spending mandate is PROPOSITION 44, which the SOS summary describes as requiring "nonprofit Federally Qualified Health Centers (community clinics that provide primary care to medically underserved areas and populations) to spend at least 90% of their revenue on program services" — both go to voters November 3, 2026. Prop 45's relevance to health centers runs through project permitting, since "essential projects" include hospitals and health care facilities, and the California Primary Care Association, the California Hospital Association, and the California Children's Hospital Association have announced support; it is a rival for voter attention, not a legal counterweight to Prop 44. This entry's earlier speculation that competing measures could "block each other" does not appear to apply, since Props 44 and 45 regulate different subjects — that is our reading, not a legal determination, as California's conflicting-measures rule is resolved on provision-level conflict by the courts, and the conflicting-measures question we are actively tracking on this ballot is Prop 40 vs. Props 41/42 (SOS qualified-measures page verified July 31, 2026; it carries no publication date and does not name CalChamber, so the Prop 45 identity is corroborated by CalChamber, CalMatters, and outside counsel analysis).
Aug 31, 2026(9 days)— RESOLVED — no floor vote is coming. leginfo location now reads "Sen Inactive File" (read 2026-08-04). Released from suspense May 14 on a 5-2 do-pass-as-amended, ordered to third reading May 18, then "Ordered to inactive file" June 8, 2026 — the last recorded action. See the outcome below.
SB 1422 survived the Appropriations suspense file — released May 14, 2026 on a 5-2 do-pass-as-amended vote — but never converted that into a floor vote. It was read a second time and ordered to third reading May 18, 2026, then sat: the Senate's house-of-origin deadline of May 29, 2026 passed with no third-reading vote, and on June 8, 2026 the bill was "Ordered to inactive file," with no Senate floor vote, no Assembly referral, and no action of any kind logged since. Having missed its house-of-origin deadline, the bill is effectively stalled for the 2025-26 session — it can only move again if the Senate Rules Committee grants a rule waiver, and no waiver is on the record; absent that it dies when the session ends. The bill's subject as filed is "Medi-Cal: eligibility: immigration status"; the source names no FQHC or Section 330 health center, so the health-center impact is our inference.
The confusion was resolved in FQHCs' favor: on May 7, 2026 — four days before the May 11 cliff — HHS OCR issued its own Interim Final Rule (Fed. Reg. 2026-09266) extending the Section 504 / WCAG 2.1 AA deadline by one year, to May 11, 2027 (15+ employees) and May 10, 2028 (<15), so HHS did match the DOJ Title II extension after all. Section 504 itself remains enforceable since July 8, 2024, so the underlying obligation (and private right of action) is unchanged.
Sep 30, 2026(39 days)— En banc GRANTED — watch for en banc argument scheduling and the full-court merits decision on the WV + MD contract-pharmacy laws
On May 28, 2026 the full Fourth Circuit GRANTED en banc rehearing of the challenges to both West Virginia's S.B. 325 and Maryland's 340B contract-pharmacy law — the opposite of a denial, so no Supreme Court petition followed. The panel decisions that had sided with drugmakers will be reheard by the full court; a merits decision is pending. Favorable for preserving state-level 340B protections (and the circuit-split posture relevant to CA AB 1460).
Nov 3, 2026(73 days)— June 25 = final ballot qualification deadline. Verification results will determine whether initiatives proceed.
Both initiatives cleared signature verification — the procedural gate this entry was watching. #25-0008 is certified for the November 3, 2026 ballot as PROPOSITION 44, titled by the Secretary of State "Requires community health clinics spend 90% of revenue on program services. Initiative statute."; the $450K executive-pay cap (#25-0009) also qualified — May 12, 2026, tracked by the Secretary of State as Initiative 1985 and never assigned a proposition number — and was formally withdrawn on June 25, 2026 per the SOS "Withdrawn or Failed to Qualify" list. Press reporting (Becker's, CMA, edhat) attributes that withdrawal to a mutual-disarmament deal announced June 24 between SEIU-UHW and the California Hospital Association, brokered by the California Federation of Labor Unions, under which CHA also pulled its union-spending countermeasure #25-0021; the SOS record itself states only the withdrawal, not a reason — so the exec-pay cap fell for negotiated reasons, not for want of valid signatures. Scope note: #25-0009 applied to private hospitals, private physician groups, and special-district public hospitals — a companion pressure measure, not itself FQHC-scoped.
Sep 30, 2026(39 days)— No 2026 reconciliation markup occurred — Senate Finance got no reconciliation instructions; the health-center funding fight has moved to FY2027 appropriations and the Dec 31 CHC Fund cliff
The anticipated mid-May 2026 Senate Finance reconciliation markup did NOT occur — Senate Republican leadership pursued a narrow reconciliation package with no reconciliation instructions to the Senate Finance Committee, so no NEW health-center cuts advanced via reconciliation. NACHC's $7B / 7.6M-patients / 1-in-5-closures figures remain its standing estimate of the already-enacted H.R. 1's 10-year impact; the live federal funding threat is now FY2027 appropriations and the December 31, 2026 CHC Fund cliff.
Jan 10, 2027(141 days)— Signed-budget outcome: UIS adult dental and the related clinic-payment exposure were delayed to July 1, 2027; this campaign now tees up the 2027 renewal fight.
The May 14 May Revision held the line on neither ask: it kept the then-proposed July 1, 2026 elimination of full-scope UIS adult dental and proposed raising the UIS monthly premium to $50 — a premium already scheduled to begin at $30 on July 1, 2027. The enacted 2026-27 budget then delayed the immediate Medi-Cal dental cuts for people with unsatisfactory immigration status (UIS) by 12 months to July 1, 2027, and prevented the increase to $50 for UIS Medi-Cal enrollees next year; the next Governor will decide in next year's budget whether the $30 premium rises (Health Access California / Health4All coalition, June 30, 2026). The same release credits the coalition with pushing dental cuts and clinic payment reductions to 2027. Read it as a one-year delay, not a repeal.
Sep 15, 2026(24 days)— CLOCK EXPIRED: the ICR comment window closed July 15, 2026 (AHA filed its comment that day). HRSA synthesis expected 30-60 days post-deadline → next check ~Sept 15. Note the id says 'april-27-2026-deadline' but this is the SECOND, distinct window — the April RFI closed Apr 20; this June ICR closed Jul 15. The id is misleading and should be renamed or split. HRSA's own burden estimate: ~15,250 covered entities / ~4M annual hours (≈260 hrs/entity/yr) — the first quantified admin-cost figure for the pilot.
Both comment windows closed; AHA/ASHP/NACHC/WHA filed formal opposition arguing >$1B/year cost
Sep 1, 2026(10 days)— June 10 = WA SB 5981 effective date. Court must rule on preliminary injunction before then. If no injunction, law takes effect and CA AB 1460 path clears.
Preliminary injunction denied June 9, 2026 — Judge David Estudillo (W.D. Wash.) held that AbbVie, Novartis and PhRMA had not shown a likelihood of success on their preemption and constitutional claims, writing that the theory "requires too much of a stretch in assuming Congress's intent" and expressly limiting the finding to "this stage" (AstraZeneca was a plaintiff but did not seek the injunction). The law is now in effect, carrying civil penalties up to $5,000 per day per violation with each package of 340B drugs counted as a separate violation, though sources conflict on the exact effective date: the Washington State Hospital Association and Washington State Standard both report June 11, 2026, while at least one law-firm analysis says June 10. The plaintiffs have appealed to the Ninth Circuit, so the ruling is not final. Our reading for California — the sources do not address California, AB 1460 or health centers: a preliminary-injunction denial is not a merits ruling, and the state 340B landscape remains split, with North Dakota's contract-pharmacy law permanently enjoined April 27 and the Fourth Circuit granting en banc rehearing of the West Virginia and Maryland cases May 28; AB 1460 shows no legislative activity in the entire 2026 session and should be treated as likely dead for the session, with September 12 the next real checkpoint, not as a bill awaiting a hearing.
Aug 28, 2026(6 days)— Still unresolved — HRSA has issued NO guidance allowing or barring the mandates. Lilly's June 1 letter set a June 8 cutoff to pull 340B pricing from non-compliant entities (~70% complied, ~1,000 holdouts); 9 manufacturers now require data. Watch for HRSA action and any fallout from the June 8 cutoff
Sep 1, 2026(10 days)— Monitor for circuit ruling by Q3 2026. Outcome shapes which state-law model (Vermont, Washington, Maine) provides the strongest precedent for any future CA AB 1460-style 340B contract pharmacy access legislation.
Sep 1, 2026(10 days)— Track exemption criteria and verify each state's July, August, or September outreach month from its selected applicant lookback
Published as CMS-2454-IFC (Federal Register document 2026-11094, publication date June 3, 2026): 80-hour/month community-engagement requirement, effective July 31, 2026, with full state implementation by January 1, 2027. CORRECTION (verified August 2, 2026 against the printed DATES section at 91 FR 33348): comments must be received by July 31, 2026, and the regulations also become effective July 31, 2026. A prior update relied on the Federal Register API's null comments_close_on field and incorrectly treated the comment deadline as unverified; the published PDF expressly states both dates.
This record cannot be verified and needs a dated primary artifact or should be considered for removal: its own source, ccalac.org/advocacy/, is a member login page, and the summit's April 14, 2026 date, its "60+ Southern California FQHCs" attendance figure and its stated themes are unconfirmed from any accessible source. The "Congressional reconciliation timeline" question cannot be answered as framed — H.R. 1, the reconciliation vehicle carrying the Medicaid cuts, was enacted July 4, 2025, roughly nine months before the stated summit date. On the May Revision question, answered from other sources: the May 14, 2026 May Revision retained the UIS enrollment freeze, the July 1, 2026 UIS adult dental elimination and the Medi-Cal Dental supplemental cut, but the budget signed June 29, 2026 delayed the ~$1B UIS-PPS clinic cut, the UIS adult dental elimination and the Prop 56 dental supplemental cut 12 months to July 1, 2027 via a $1,034,000,000 General Fund appropriation and renewed the MCO tax, while the Legislature's $125M county indigent-care ask was excluded — a one-year reprieve, not a repeal, per the June 11, 2026 Assembly Budget Committee Floor Report and the Governor's June 29, 2026 signing release. No attribution of that budget outcome to this summit's advocacy is established.
Oct 1, 2026(40 days)— Track briefing schedule and any HRSA response; a ruling narrowing the patient definition would require FQHC 340B programs to re-verify eligibility workflows.
OFF THE NOVEMBER BALLOT — withdrawn, not defeated: it was not rejected at the polls and did not fail signature verification. CHA's #25-0021 ("Restricts Political Spending by Health Care Unions," proponent Carmela Coyle/CHA) became eligible for the November 3, 2026 ballot in early June 2026, then was affirmatively pulled on June 24, 2026 — one day ahead of the June 25 statutory deadline — under a mutual-disarmament deal between SEIU-UHW and the California Hospital Association brokered by the California Federation of Labor Unions, which also pulled SEIU-UHW's $450,000 executive-pay cap (#25-0009); neither measure appears among the 14 statewide propositions the Secretary of State certified for November 3. The deal did NOT touch the FQHC-direct 90% clinic-spending mandate (#25-0008), which remains on the certified list and is carried in our records as Proposition 44 per the SOS-verified numbering, nor the billionaire wealth tax. Sourcing note: the Sacramento Bee account is paywalled and could not be content-verified; the facts above are corroborated by Ballotpedia's certified-measure list (June 26, 2026), CalMatters (June 25, 2026), and ABC10.
WITHDRAWN — not defeated. California's official withdrawn-measures registry records the $450,000 health-executive compensation cap (#25-0009A1 / Measure 1985) and the CHA-backed healthcare-union political-spending measure (#25-0021A1) as withdrawn on June 25, 2026, the statutory deadline to pull initiatives off the November 3 ballot; reporting (Sacramento Bee, announced by the California Federation of Labor) attributes the paired withdrawals to a mutual-disarmament deal between SEIU-UHW and the California Hospital Association. Independently verified July 31, 2026 against the Secretary of State's qualified-measures list, which shows 14 measures for November 3, 2026 (Propositions 1-5 and 37-45) and contains no executive-compensation measure; the FQHC-direct 90% clinic-spending mandate (#25-0008) was NOT part of the deal and remains on the ballot as Proposition 44. Scope caveat: this measure never named FQHCs or community clinics as covered entities — per the LAO analysis it applied to hospitals and physician groups with 25+ employees, excluding county hospitals, sub-25-employee physician groups, and the VA — so it was always the flanking measure, not the FQHC-direct threat.
Nov 3, 2026(73 days)— Signature verification deadline — check if measures qualify for November ballot
SPLIT OUTCOME. The 90% mission-spend measure (#25-0008 / Measure 1986) is on the November 3, 2026 ballot as PROPOSITION 44, and the Secretary of State's certified title — "REQUIRES COMMUNITY HEALTH CLINICS SPEND 90% OF REVENUE ON PROGRAM SERVICES. INITIATIVE STATUTE." — describes it as covering "nonprofit Federally Qualified Health Centers (community clinics that provide primary care to medically underserved areas and populations)," so the FQHC scope is stated by the state, not inferred by us. The companion Healthcare Executive Compensation Act (#25-0009 / Measure 1985), which qualified May 12, 2026, does not appear anywhere on the SOS certified list; per separate reporting — NOT the SOS page — SEIU-UHW and the California Hospital Association announced a mutual-disarmament deal on June 24, 2026, one day ahead of the June 25 statutory withdrawal deadline, pulling #25-0009 together with CHA's union-political-spending counter-measure (#25-0021), and sources differ on whether to date the withdrawal to the announcement or the deadline. Neither the billionaire-wealth-tax measure (now Proposition 40) nor Prop 44 was affected by that deal. Data-hygiene note: this entry's opposition-funding figures — $28.3M against SEIU-UHW's $17.8M — are an April 11, 2026 snapshot and should not be read as current, since the opposition has organized as the named "No On Prop 44" committee sponsored by CPCA Advocates; verified against the SOS qualified-measures list on July 31, 2026, a page that carries no publication timestamp, so the evidence date is our verification date.
AB 1113 DIED on January 31, 2026 as a two-year bill (Calif. Const. Art. IV §10(c)) — it cleared an Assembly policy committee 11-1 (May 2025) but stalled on the Appropriations suspense file and never reached the Assembly floor. The SEIU-UHW 90% mission-spend effort now runs solely through the qualified ballot measure (Initiative #25-0008 / Measure 1986, Nov 3, 2026), which CPCA and Open Door Community Health Centers are suing in federal court to block. CPCA's opposition has shifted entirely from the bill to the ballot and the lawsuit.
Nov 3, 2026(73 days)— RESOLVED — signatures were sufficient. The measure qualified June 17, 2026 and is on the November 3, 2026 ballot as PROPOSITION 40. Newsom rejected the union's offer to withdraw it in exchange for a smaller 2% legislative levy (June 18). Watch two things on election night, not one: Prop 40's own result, AND Props 41/42 — under California's conflicting-measures rule the measure with the higher vote total prevails, so Prop 40 can pass and still be nullified. Scenario-weight it; do not bank it. UPDATE (Aug 6, per CalMatters coverage of the campaign, July 30): the labor coalition itself is split — parent union SEIU California voted to stay NEUTRAL on Prop 40 despite its own subsidiary SEIU-UHW having authored and championed it, alongside other unions (teachers/police/firefighters) opposing on the grounds it disproportionately benefits the healthcare sector at the expense of other budget priorities. Opposition spending is also material: tech entrepreneur Sergey Brin (who relocated to Nevada) has spent $82M opposing the measure — present the balanced picture in any coverage, not just the health-sector case for it.
Correction to our record: en banc rehearing was GRANTED, not denied. On May 28, 2026 (reported by AHA May 29) the full Fourth Circuit agreed to rehear the challenges to West Virginia's S.B. 325 and Maryland's 340B contract-pharmacy law, after the three-judge panel had ruled against those laws (the West Virginia panel decision March 31, 2026; Maryland in April), and a merits decision from the full court is pending. Our reading — not stated by the source — is that under Fourth Circuit Rule 35(c) an en banc grant vacates the panel judgment, so the panel decision recorded here should no longer be treated as binding circuit precedent; confirm against the docket before relying on that. The source does not address any Supreme Court petition and does not mention FQHCs or Section 330 health centers, and any read-across to the Washington SB 5981 or California AB 1460 challenges is our analysis, not the court's.
Sep 1, 2026(10 days)— Injunction DENIED June 9; law in effect June 10. Litigation continues on the merits — watch for appeal to the 9th Circuit and any Supreme Court cert petition consolidating the WV/MS circuit split. Read alongside CA AB 1460 (pending in Senate Health; no confirmed 2026 hearing date).
Preliminary injunction denied June 9, 2026 (Judge Estudillo); SB 5981 took effect June 10, 2026 with $5,000/day penalties. Merits litigation continues.
Sep 1, 2026(10 days)— Monitor district court remand proceedings through Q3 2026. Discovery filings could surface evidence usable in California AB 1460-style legislation. NACHC and 340B Health are coordinating amicus briefs.
Resolved April 17, 2026: the FAR Council issued guidance implementing Executive Order 14398 ("Addressing DEI Discrimination by Federal Contractors," signed March 26, 2026), adopting model deviation clause FAR 52.222-90, with agencies directed to include it in solicitations and contracts beginning April 24, 2026 and to seek bilateral modification of existing contracts by July 24, 2026; the clause requires contractors to certify they do not operate "racially discriminatory DEI activities," requires cooperation with agency information requests, contemplates termination, suspension and debarment, and states that compliance is material to the Government's payment decisions under the False Claims Act, 31 U.S.C. § 3729(b)(4). The FQHC read is our inference, not a source statement — none of the EO 14398 guidance or law-firm analyses we reviewed mention FQHCs, health centers, HRSA or Section 330; FAR clauses attach to federal procurement contracts while Section 330 awards are federal financial assistance governed by 2 CFR Part 200, so we read Section 330 grantees as outside FAR 52.222-90, with health centers holding separate federal procurement contracts or subcontracts in scope for those. Do not read this as "no DEI risk for health centers": DEI conditions have reached federal financial assistance through separate channels — agency grant and cooperative-agreement terms added independently of EO 14398, HHS/OMB grant conditions such as MAHA's DEI deprioritization, and DOJ civil investigative demands issued to grantees as well as contractors — and those are tracked separately as an open watch item. Whether agencies completed the July 24, 2026 contract-modification effort is not verified; no public deliverable was identified, and this is an internal agency contracting process with no direct Section 330 consequence.
The recorded May Revision and signed-budget outcome stands — the substantive relief came from the budget, not from SB 1422. Per the Legislature's own bill-status record, SB 1422 sat at Senate Third Reading from May 18, 2026 without a floor vote and was ordered to the inactive file on June 8, 2026, with no action since and no Assembly referral; an inactive-file placement is reversible — an author can move a bill back to third reading while the session is live, and the last day for each house to pass bills is August 31, 2026 — so the bill is stalled rather than formally dead. Our read (inference, not a docket statement): because the house-of-origin deadline for second-year bills fell on May 29, 2026 and SB 1422 had not passed the Senate by then, revival would require a rule waiver, and absent that the bill expires with the 2025-26 session on November 30, 2026 and restoration would need a new bill in 2027. Re-check after August 31, 2026 to confirm.
Oct 31, 2026(70 days)— Check working group progress and whether layoffs proceed
Partially resolved: on June 25, 2026 the Alameda County Board of Supervisors unanimously adopted a $6.7B FY2026-27 budget that closed a ~$91.4M gap without county layoffs and allocated up to $19.3M in one-time funding to Alameda Health System, after which AHS rescinded the 92 layoffs scheduled for July 6, 2026; the same funding pays for an outside performance audit and extends two behavioral health programs through October 31, 2026, and the budget separately carries an $85.3M community health center line. The rescission covers 92 positions, not the full ~188-position reduction deferred in March, so the balance of the deferred cuts is not accounted for by this action. The $19.3M is one-time and audit-conditioned — AHS still projects roughly a $100M FY2026-27 deficit and ~$100M/yr in lost revenue by 2030, so the fiscal imbalance is bridged, not closed — and sources differ on the money's origin, with Becker's describing it as state funding and county coverage as a county allocation. Any downstream effect on East Bay Section 330 health centers is our inference; the next decision points are the October 31, 2026 behavioral health extension and the performance audit findings.
Nov 3, 2026(73 days)— On the Nov 3, 2026 ballot. Watch the result and, if it passes, whether any share is earmarked for community clinics — the qualifying coverage does NOT break out a health-care or FQHC allocation.
QUALIFIED for the November 3, 2026 ballot as the "Protect San Diego's Health and Safety Act" — and by a different route than this entry anticipated. It reached the ballot by citizens' petition, not Board referral: the County Registrar certified more than 121,000 valid signatures against roughly 103,000 required. The measure is a half-cent sales tax increase (7.75% to 8.25%) projected to raise about $360 million a year for Tijuana River Valley sewage response, wildfire response, and backfilling health and social programs cut at the federal level. It expressly bars spending on elected-official salaries, executive bonuses, lobbying contracts, and county office construction. Supporters include SEIU 221, the San Diego County Hospital Association, AAP California Chapter 3, Children First San Diego, and San Diego County Firefighters. IMPORTANT LIMIT: the qualifying coverage does not break out how much of the $360M would go to health care, and names no allocation to community health centers — so do not model an FQHC-specific share from this. What is established is that a county where 327,000 residents depend on Medi-Cal now has a funded local backfill mechanism on the ballot the same November as Props 40 and 44.
Jan 15, 2027(146 days)— OFFICIAL FINAL: Measure ER passed with 1,013,747 yes votes (50.64%) to 987,977 no votes (49.36%) in the LA County Registrar-Recorder count. The half-cent tax takes effect Oct 1, 2026 (countywide 9.75% -> 10.25%), raising ~$1B/yr through 2031 — ~45% to nonprofit clinics, ~22% to LA County Health Services — the largest local-government backstop for federal Medicaid cuts in the U.S., arriving while signed-budget UIS/PPS risk moves into a July 1, 2027 planning horizon. County backfill taxes now 2 wins (Santa Clara A, LA ER) vs. 1 loss (Contra Costa B, ~42%).
Passed — final count 1,013,747 yes (50.64%) to 987,977 no (49.36%) per the LA County Registrar-Recorder results. The half-cent general sales tax takes effect Oct 1, 2026 and sunsets Oct 1, 2031 (five years, ~$1B/yr), with 45% allocated to community-based nonprofit health clinics and 22% to county hospitals and clinics. Cash timing is separate from the tax start: the county expects to begin distributing Measure ER funding in January 2027 (Spectrum News, July 9, 2026), and on July 21, 2026 the Board of Supervisors authorized DHS to begin executing contracts with community-based nonprofit health clinics — so model roughly a three-month gap between the tax taking effect and funds arriving. Note that the county's own materials describe recipients as "community-based nonprofit health clinics," not FQHCs or Section 330 grantees; whether a given health center receives Measure ER funds depends on DHS contracting, which is still in progress.
Aug 31, 2026(9 days)— RESOLVED — do not watch for a floor vote. leginfo now shows Location: Sen Inactive File (read 2026-08-04), confirming the shelving recorded in the outcome below and clearing the prior 'Active Bill - In Floor Process' contradiction. Last action remains "Ordered to inactive file," June 8, 2026. Watch instead for the enrollment-freeze policy to reappear in a budget trailer bill or a new 2027 measure.
SB 1422 never received a Senate floor vote and never crossed to the Assembly: released from Appropriations 5-2 on May 14, 2026, read a second time and ordered to third reading May 18, then "Ordered to inactive file" on June 8, 2026 — the last recorded action. The record is internally inconsistent and we state the conflict rather than resolve it: leginfo still labels the bill "Active Bill - In Floor Process," Location: Senate, but the Senate's own 2026 deadlines set May 29, 2026 as the last day for each house to pass bills introduced in that house, and SB 1422 was introduced February 20, 2026 — so its house-of-origin deadline had already passed before it was shelved. (August 31, 2026 is the general last day for houses to pass bills; it governs a Senate bill once it is in the Assembly, not one still sitting in its own house.) Absent a Joint Rule waiver the bill has no ordinary path forward before sine die on November 30, 2026 — treat the Medi-Cal enrollment-freeze sunset it carried as not advancing, and watch for the policy to reappear in a budget trailer bill or a new 2027 measure rather than for SB 1422 to be revived.
Both windows have lapsed — the RFI comment period closed April 20, 2026 and the ICR burden window closed April 27, 2026 — and HRSA's post-comment direction is now on the record: it proceeded rather than paused. On June 15, 2026 HRSA published a 30-day OMB-submission ICR titled "340B Rebate Model Pilot Program Application, Implementation, and Evaluation" (OMB Number 0906-NEW, FR 2026-11989), comments closed July 15, 2026, corrected June 22, 2026 (FR 2026-12442) to raise total estimated responses from 793,080 to 793,091 "to reflect inclusion of the 11 manufacturer Pilot Program Plan submissions"; both notices were verified directly against the Federal Register API. Scope note: neither notice names FQHCs, Section 330 grantees or health centers, so the covered-entity exposure — paying WAC upfront and waiting on a rebate — is our inference from the rebate mechanism, not a statement in the rule, and sector comment positions are tracked separately. As of July 31, 2026 no Federal Register document actually launching the pilot has published, the June 22 correction being the most recent 340B-rebate-specific document; ongoing rebate-pilot tracking continues under hrsa-340b-rebate-pilot-vacated-feb-2026.
Sep 30, 2026(39 days)— SURVIVED SUSPENSE Aug 13 as amended — 'Do Pass as Amended' (5-2) on the Senate Appropriations suspense sheet; leginfo shows it read a second time and ordered to third reading Aug 17. It is the ONLY survivor of the four-bill H.R. 1 mitigation package (AB 2208, AB 2201 and SB 1202 all died the same day). IMPORTANT CAUTION: it survived AS AMENDED, and suspense amendments routinely narrow scope and cost — do not restate the pre-amendment description of what this bill does until the amended text is read. Next gate: Senate floor vote by Aug 31, then the Governor by Sept 30. | PRIOR NOTE: Track Appropriations + floor vote
Still open: AB 2161 passed the Assembly 58-12 on May 26, 2026 and cleared Senate Health 8-2 on July 1 (history posted 07/02/26), and now sits in Senate Appropriations, which leginfo lists as "Active Bill - In Committee Process" with no vote scheduled. Per the Legislature's 2026 calendar, fiscal committees must report bills to the floor by August 14 and each house must pass bills by August 31, with the Governor's sign-or-veto deadline September 30. Watch the Senate Appropriations suspense file first — this bill was held on Assembly Appropriations suspense from April 29 to May 14, and a bill can die on suspense by inaction before August 14 without any recorded vote. Re-check after the Senate Appropriations suspense hearing and again after August 31; keep the status as active/in-committee rather than pending-vote until a hearing or floor vote is actually calendared.
The litigation over the first 340B rebate pilot concluded against HHS — per our tracking, HHS withdrew its appeal February 5, 2026 and the District of Maine vacated and remanded the pilot February 10, 2026 (the suit was brought by hospital associations; health centers benefit as covered entities but were not plaintiffs). HRSA has since restarted: a revised rebate-pilot Information Collection Request published in the Federal Register June 15, 2026 (doc. 2026-11989, comments closed July 15), with a June 22 correction (doc. 2026-12442) anticipating manufacturer Pilot Program Plan submissions. Trade press (340B Report, July 30) reports OMB completed review of a successor "Rebate Pilot 2.0" in late July after reclassifying it as significant, but we could not verify that against a primary source. As of July 31, 2026 no Rebate Pilot 2.0 notice has published in the Federal Register — treat publication timing as unconfirmed and re-check the Federal Register before relying on it.
Sep 1, 2026(10 days)— Track potential HRSA new rulemaking + WA state pharma lawsuit (AbbVie+Novartis). UPDATE (July 13): HRSA's revived Rebate Pilot 2.0 ICR comment window closes July 15, 2026; ACH published formal opposition to including health centers (CHCs = ~5% of 340B purchases yet would pay full WAC upfront and wait for rebates) and NACHC maintains a dedicated rebate-pilot opposition page + comment letters — check post-deadline whether HRSA pauses or proceeds.
HHS withdrew appeal; program effectively vacated. Pharma's rebate model dead in current form.
Jan 10, 2027(141 days)— Signed-budget outcome: the June 29 budget delayed the dental supplemental-payment cut to July 1, 2027; watch the 2027 budget for extension or implementation.
The May 14 May Revision retained the Medi-Cal Dental cut at the proposal stage, eliminating dental supplemental payments (including Proposition 56 supplemental payments) effective July 1, 2026. CDA's own June 29, 2026 update reports that "the California Legislature and Gov. Gavin Newsom reached agreement June 26 on a State budget that protects all Medi-Cal Dental funding for another year" — a one-year reprieve, not a repeal; note that CDA states no signing date, does not name Proposition 56 supplemental payments as delayed, and does not cite a July 1, 2027 effective date, which is documented separately in the Assembly Budget Committee's June 11, 2026 Floor Report. The provider-side dental supplemental-payment cut and the separate patient-side UIS adult dental benefit elimination are two distinct cuts that happen to share the delayed effective date — do not sum them or describe them as one cut. Watch the January 10, 2027 Governor's Budget for extension or implementation.
Aug 31, 2026(9 days)— Track preliminary motion phase + HHS response to Maine vacatur
The Maine case is identified and the plaintiffs won the preliminary phase: American Hospital Association v. Kennedy, No. 2:25-cv-00600 (D. Me.), filed December 1, 2025 by AHA, the Maine Hospital Association and four hospitals — no FQHC is a plaintiff — with an order granting the TRO/preliminary injunction issued December 29, 2025 (verified on CourtListener RECAP), the First Circuit denying the government's stay request in early January 2026, and the 340B Rebate Model Pilot notice subsequently vacated and remanded to HRSA, so upfront 340B discounts remain in place. Two caveats: our own records disagree on the vacatur date — two entries put it at February 10, 2026 (joint motion granted) while this item's summary says April 2026, and we have not read the order itself, so February is the better-corroborated of the two; and the frequently-cited guardrail of fresh notice-and-comment plus an effective date no earlier than 90 days after manufacturer-application approvals is recorded as HRSA's own commitment and/or a term of the parties' joint vacatur motion, NOT verified as a requirement imposed by the court. Separately, and not evidenced by this docket, HRSA moved to a Rebate Pilot 2.0 (Federal Register ICR June 15, 2026, comments closed July 15, 2026), which the OMB reclassified "economically significant" in late July. UPDATE (Aug 6, 2026): the revised 340B Rebate Model Pilot Program was published in the Federal Register on August 3, 2026 (document 2026-15633), confirming the prior unverified report — manufacturer rebate-plan submissions are due August 24, 2026, HRSA approvals by September 24, 2026, and the program takes effect January 1, 2027, covering NDC-11s of drugs selected under the Medicare Drug Price Negotiation Program for initial price years 2026/2027.
Approved by voters on November 5, 2024 as Proposition 35. The 2024 coalition was broad rather than anti-labor — SEIU California's executive director was quoted in support, and SEIU California is the state council, a separate entity from SEIU-UHW. Proposition 35's provider rate increases run on their own schedule and depend on continued federal approval of the MCO tax; check current status against DHCS and the CMS approval window before treating them as fully in effect.
The court denied the health centers' temporary restraining order and the Medi-Cal Rx carve-out took effect January 1, 2022 as scheduled. Coverage places U.S. District Judge John Mendez's denial in early January 2022; the exact order date is not confirmed against the docket here, and the case's final disposition is not established — so read this as a lost preliminary bid, not a conclusively decided case. California's live 340B question is a different one: about 2 million Unaffordable Insurance Subsidy (UIS) enrollees move from Medi-Cal managed care to fee-for-service on January 1, 2027, which we track separately.