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Advocacy watch

Legislation, ballot measures, coalition actions, and court rulings that protect FQHC funding, with follow-up dates, outcomes, and ways to act.

Updated: 2026-10-01

114

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Upcoming follow-up dates

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Schedule in Massachusetts v. Oz (D. Mass. No. 1:26-cv-12962): the August 6 scheduling order (Dkt. 100) sets the federal government's opposition and cross-motion for summary judgment for September 18, the states' reply and opposition for September 28, and the government's reply for October 7. The summary-judgment hearing is October 20, 2026 at 2:00 p.m. before Judge Stearns, in person only (Dkt. 101). The states moved for partial summary judgment September 1 (Dkt. 103). Four amicus briefs supporting the states were docketed September 10-15 (Dkts. 113, 119, 121 and 126). Only Dkt. 113, filed for the American Public Health Association, 161 deans, chairs and scholars and other organizations, addresses community health centers: it cites the administrative record that half of health-center patients are covered by Medicaid and an estimate of $16-32 billion in lost health-center reimbursement over five years. Dkt. 119 (the AMA, the Massachusetts Medical Society and nine other medical associations), Dkt. 121 (the National Health Law Program, the Center for Public Representation and 69 other organizations) and Dkt. 126 (five mental-health organizations, including the American Psychiatric Association and the National Council for Mental Wellbeing) do not discuss health centers. FILED

25 States + DC Sue HHS/CMS Over the Work-Requirement Ru...

Oct 7, 2026·Georgetown University Center for Children and Families (updated July 14, 2026)

days

As of September 16, 2026, no removal to federal court, responsive pleading or ruling has been reported since the July 22 filing, and federal court records show no removed case. What to watch: the defendants' responsive pleadings (removal to federal court is the likely first move) and any preliminary ruling on the Deceptive Trade Practices Act theory. For California, the question this case tests

Arkansas AG sues 13 drugmakers + a data firm under the ...

Oct 15, 2026·Arkansas Advocate

days

Check for ALJ ruling on forced recognition

NLRB Seeks Forced Union Recognition at Innercare — ALJ ...

Oct 15, 2026·SEIU-UHW Innercare ULP pa...

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RE-CHECKED 2026-09-03: STILL UNRESOLVED. The American Hospital Association stated on 2026-08-11, verbatim, that “to date, we are unaware of any action HRSA has taken to address these policies.” AHA wrote HRSA on January 26, March 3 and April 27 with no response. The policy has spread

Eli Lilly & Novo Nordisk Activate 340B Claims-Data Mand...

Oct 15, 2026·AHA — HRSA urged to halt ...NACHC 340B Policy Resourc...

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Five manufacturer suits challenge HB 2371 in the Northern District of Illinois (AbbVie, Novartis, Bristol Myers Squibb, AstraZeneca and PhRMA; lead docket No. 1:26-cv-09522 before Judge Edmond E. Chang). Preliminary-injunction motions are pending: the state responded September 4, the plaintiffs' joint reply is due September 23, and a tracking status hearing was set for September 25. A September 24 order cancelled the scheduled hearings; as of October 2 the docket shows no ruling on the injunction motions. Watch for that ruling.

Illinois Governor Signs HB 2371 and HB 4327 — Contract-...

Oct 16, 2026·Official enrolled HB 2371...Official enrolled HB 4327...

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October 1, 2026: no rehearing or Supreme Court petition found yet. The 90-day certiorari window from the July 21 judgment closes around October 19. HRSA's own revised pilot starts January 1, 2027.

D.C. Circuit rules manufacturers can't impose a 340B re...

Oct 20, 2026·American Hospital Association

114 actions

In CourtLegal ActionCalifornia

CPCA and five health centers sue SEIU-UHW under federal racketeering law

Nov 3, 2026(29 days)— Case no. 2:26-cv-03311 (E.D. Cal.), assigned to Judge Dena M. Coggins. The complaint's claims are allegations. Watch for service, SEIU-UHW's answer or motion to dismiss, and any request for relief before the November 3 vote. Joint status report due January 5, 2027.

Pending VoteBallot InitiativeCalifornia

The official Prop 44 voter guide names nonprofit FQHCs, authorizes criminal charges, and gives the first neutral number in the fight: clinics already spend about 80% of revenue on care

Nov 3, 2026(29 days)— Election day is November 3, 2026. The first public poll to ask about Prop 44 is out: in the PPIC Statewide Survey conducted September 4-10, 2026 and released September 16, 34% of likely voters said they would vote yes and 61% no after reading the ballot title and label. PPIC reports support of roughly one in three across partisan groups and about four in ten or fewer across demographic and regional groups; the survey reached 1,745 adults online in English and Spanish, and the likely-voter sampling error is ±3.8 points. The UC Berkeley IGS poll fielded August 3-9 did not ask about Prop 44, so there is no earlier reading to compare against. One survey is a snapshot, not a forecast.

ActiveCoalition ActionLos Angeles County

Measure ER campaign organizers launch Health Justice United, a Los Angeles County coalition focused on how Measure ER funds are allocated

Dec 1, 2026(57 days)— Check whether Health Justice United publishes a member list or takes public positions on how Los Angeles County allocates Measure ER revenue, including the share directed to community clinics.

Signed Into LawLegislationIllinois

Illinois Governor Signs HB 2371 and HB 4327 — Contract-Pharmacy Protections Become Law Alongside a State 340B Transparency Study

Oct 16, 2026(11 days)— Five manufacturer suits challenge HB 2371 in the Northern District of Illinois (AbbVie, Novartis, Bristol Myers Squibb, AstraZeneca and PhRMA; lead docket No. 1:26-cv-09522 before Judge Edmond E. Chang). Preliminary-injunction motions are pending: the state responded September 4, the plaintiffs' joint reply is due September 23, and a tracking status hearing was set for September 25. A September 24 order cancelled the scheduled hearings; as of October 2 the docket shows no ruling on the injunction motions. Watch for that ruling.

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. HB 2371 is Public Act 104-0758 and HB 4327 is Public Act 104-0769, both effective August 7, 2026.

ActiveFederal ActionFederal

NACHC advocacy lands a 45-0 House Energy & Commerce vote advancing $750M for health-center behavioral health and nutrition

ActiveFederal ActionFederal

66 House members ask CMS for telehealth payment parity at health centers and rural clinics; NACHC backs the letter

Nov 1, 2026(27 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.

ActiveCoalition ActionSan Diego

San Diego Regional Chamber of Commerce comes out against Proposition 44 — the first general business group to join what had been a health-sector-only opposition

Nov 3, 2026(29 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.

ProposedLegislationFederal

Sen. Padilla and the Congressional Tri-Caucus reintroduce the Health Equity and Accountability Act, with FQHC workforce and safety-net provisions

Jan 15, 2027(102 days)— October 1, 2026: S. 5066 was referred to Senate Finance July 22, 2026, with no action since. It expires with the 119th Congress on January 3, 2027. Check for reintroduction in the 120th.

ActiveLegal ActionFederal

Arkansas AG sues 13 drugmakers + a data firm under the state's own 340B shield law — the first state to go on OFFENSE rather than defend a law from manufacturers

Oct 15, 2026(10 days)— As of September 16, 2026, no removal to federal court, responsive pleading or ruling has been reported since the July 22 filing, and federal court records show no removed case. What to watch: the defendants' responsive pleadings (removal to federal court is the likely first move) and any preliminary ruling on the Deceptive Trade Practices Act theory. For California, the question this case tests — whether a state 340B shield law matters without an attorney general willing to enforce it — now waits for 2027: AB 1460 died without a 2026 hearing when the Legislature's August 31 deadline passed.

ProposedLegislationFederal

Bipartisan Senate 340B working group expected to release a legislative draft before the August recess — a third federal 340B vehicle

Nov 3, 2026(29 days)— RESOLVED 2026-09-03: the draft WAS released on 2026-08-05 as the SUSTAIN 340B Act discussion draft from the bipartisan Senate working group (Moran, Baldwin, Capito, Kaine, Boozman, Hickenlooper). We already track it separately. CAUTION on language: some member press releases and trade coverage say the senators “introduced” it, but no bill number exists and it is a discussion draft — do not describe it as introduced. Next: watch for formal introduction and for how it collides with HRSA’s rebate pilot, which it would end within one year.

In CourtLegal ActionFederal

D.C. Circuit rules manufacturers can't impose a 340B rebate model without HHS approval

Oct 20, 2026(15 days)— October 1, 2026: no rehearing or Supreme Court petition found yet. The 90-day certiorari window from the July 21 judgment closes around October 19. HRSA's own revised pilot starts January 1, 2027.

ActiveBallot InitiativeCalifornia

CPCA joins CHA and the Children's Hospital Association to endorse Prop 45, a 2026 measure to speed health-facility approvals

Nov 3, 2026(29 days)— Track through the November 3, 2026 general election.

ActiveBallot InitiativeCalifornia

The FQHC Sector's November Defense Goes Live: 'No on Prop 44' Launches With 100+ Health Centers, the CMA, Planned Parenthood and the CTA

Nov 3, 2026(29 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. The League of Women Voters of California also recommends a NO vote, saying Prop 44 'could diminish access to health care for Californians who already have limited options.' UPDATE (Oct 2): the Legislative Analyst's neutral baseline is that clinics already spend about 80% of revenue on health care services, and state enforcement would cost the low tens of millions of dollars a year, paid by fees on affected clinics; the BRG $1.7B figure is opposition-commissioned. On September 18, CPCA and five health centers filed a federal RICO suit against SEIU-UHW (see cpca-v-seiu-uhw-rico-suit-sept-2026).

In CourtLegal ActionFederal

NACHC and RWC-340B Move to Intervene to Defend HRSA's 340B 'Patient' Definition Against AbbVie

PassedFederal ActionFederal

NACHC Rulemaking Win: CMS Preserves the 35% Essential Community Provider Requirement in the 2027 Marketplace Final Rule

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.

ActiveLegislationFederal

Bipartisan SECURE 340B Act (H.R. 9599) Introduced — Pauses the Rebate Model Four Years, Sets a Statutory Patient Definition

Nov 3, 2026(29 days)— RE-CHECKED 2026-09-03 against the official bill-status record: still in committee. No markup, no hearing, no Senate companion. Latest action remains the 2026-07-06 referral to Energy & Commerce, Ways & Means, and Education & Workforce. One movement since our last check: Rep. Carol D. Miller (R-WV-1) joined as a cosponsor on 2026-08-31. Verify the exact cosponsor count on congress.gov before publishing a number — the bulk-data count field appears to lag the cosponsor records.

In CourtLegal ActionFederal

8th Circuit Rejects Novartis's Bid to Block Missouri's 340B Contract-Pharmacy Law (Novartis v. Hanaway, No. 25-1619)

Oct 28, 2026(23 days)— UPDATE (Sept 16): the 8th Circuit denied Novartis's petitions for rehearing en banc and for panel rehearing in No. 25-1619. Judges Kobes, Justin D. Smith and Traynor would have granted en banc review; Judge Traynor, joined by Judge Smith, dissented, writing that the United States' amicus briefing in this case warrants reconsidering the precedential value of the court's decision in PhRMA v. McClain. Judges Gruender, Kelly and Grasz did not participate. The July 1 affirmance stands, so S.B. 751's contract-pharmacy protections remain in force against Novartis while the case continues in the district court. What to watch: whether Novartis asks the U.S. Supreme Court to review the decision (a petition would be due within 90 days of the denial), the district-court merits proceedings, and the 4th Circuit's October 27 en banc argument in the West Virginia and Maryland cases.

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.

In CourtLegal ActionFederal

25 States + DC Sue HHS/CMS Over the Work-Requirement Rule's 'Medically Frail' Exemption — Massachusetts v. Oz, Bonta Co-Leads

Oct 7, 2026(2 days)— Schedule in Massachusetts v. Oz (D. Mass. No. 1:26-cv-12962): the August 6 scheduling order (Dkt. 100) sets the federal government's opposition and cross-motion for summary judgment for September 18, the states' reply and opposition for September 28, and the government's reply for October 7. The summary-judgment hearing is October 20, 2026 at 2:00 p.m. before Judge Stearns, in person only (Dkt. 101). The states moved for partial summary judgment September 1 (Dkt. 103). Four amicus briefs supporting the states were docketed September 10-15 (Dkts. 113, 119, 121 and 126). Only Dkt. 113, filed for the American Public Health Association, 161 deans, chairs and scholars and other organizations, addresses community health centers: it cites the administrative record that half of health-center patients are covered by Medicaid and an estimate of $16-32 billion in lost health-center reimbursement over five years. Dkt. 119 (the AMA, the Massachusetts Medical Society and nine other medical associations), Dkt. 121 (the National Health Law Program, the Center for Public Representation and 69 other organizations) and Dkt. 126 (five mental-health organizations, including the American Psychiatric Association and the National Council for Mental Wellbeing) do not discuss health centers. FILED — docket re-read September 21, 2026: the government met its September 18 date. Entry 138, filed 2026-09-18, is a “Cross MOTION for Summary Judgment and Opposition to Plaintiffs’ Motion for Summary Judgment by Centers for Medicare & Medicaid Services, Robert F. Kennedy, Jr, Mehmet Oz, U.S. Department of Health and Human Services (HHS),” with attachments including a memorandum in support and the defendants’ statement of facts. The brief itself is available only through PACER and has not been read, so how CMS defends the added significant-impairment test is not yet characterized here. The states met their September 28 date: entry 140, filed 2026-09-28, is a “REPLY to Response to 138 Cross MOTION for Summary Judgment and Opposition to Plaintiffs’ Motion for Summary Judgment” filed by the Commonwealth of Massachusetts and the other plaintiffs, with a Local Rule 56.1 statement of material facts as entry 141 (docket re-read September 30, 2026). Neither brief has been read, so the states’ answer to CMS is not characterized here. No summary-judgment ruling has issued. The October 20 hearing is still on the docket as set: 2:00 p.m., Courtroom 21, in person only, before Judge Stearns. What to watch next: the government’s reply due October 7, and then the hearing. Earlier: Judge Stearns denied the preliminary injunction July 29 for failure to show irreparable harm, without prejudice, leaving CMS-2454-IFC in effect from July 31. Under 42 CFR 435.561(b)(1), states begin initial outreach in July, August or September depending on the applicant lookback period each state selects; there is no single national August 31 notification date.

Pending VoteBallot InitiativeCalifornia

The Ballot Measure That Would Fund Health Care (Prop 40) Can Be Cancelled by Two Others on the Same Ballot — Props 41 and 42

Nov 3, 2026(29 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. UPDATE (Sept 16): in the PPIC Statewide Survey fielded September 4-10, likely voters favored Prop 40 52% to 46%, Prop 41 51% to 44%, and Prop 42 54% to 43% (likely-voter sampling error ±3.8 points). All three sit within the margin of one another, so the survey does not show which measure would receive the higher vote total. UPDATE (Oct 2): CPCA opposes Prop 40. Its CEO, Francisco Silva, signed the official ballot argument against it with the California Medical Association and the California School Boards Association. The official No argument also lists the CTA, the State Building and Construction Trades Council, California Professional Firefighters and Planned Parenthood Affiliates of California as opponents; the Yes rebuttal lists the California Nurses Association among supporters.

ActiveFederal ActionFederal

Senate HELP Chair Cassidy Unveils Comprehensive 340B Reform Discussion Draft

Nov 3, 2026(29 days)— RE-CHECKED 2026-09-03: the stakeholder comment window CLOSED on 2026-08-28. The draft is still a discussion draft — no formal introduction and no bill number have surfaced, and no post-deadline HELP Committee action was found. Next step per multiple analyses is staff review of comments before any decision to introduce. Minor sourcing note: law-firm analyses date the release to June 25, 2026 while the HELP Committee’s own press page is stamped 06.29.2026 — say “late June 2026” unless you pin it.

ActiveBallot InitiativeCalifornia

Last-Minute Ballot Deal Withdraws Two Healthcare Measures — but SEIU-UHW's 90% Clinic-Spending Mandate (Measure 1986) Stays on the November Ballot

Nov 3, 2026(29 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.

Pending VoteBallot InitiativeCalifornia

SEIU-UHW Billionaire Tax QUALIFIES for November 2026 Ballot (June 17) — Newsom Rejects Union's Scaled-Back 2% Compromise

Nov 3, 2026(29 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.

ActivePublic StatementCalifornia

CPCA Advocates Endorses Xavier Becerra for California Governor — the FQHC Sector's First Gubernatorial Pick of the 2026 Cycle

Nov 3, 2026(29 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.

Pending VoteLegislationFederal

House Committee Advances School-Based Health Centers Reauthorization (H.R. 8209) with NACHC Backing

ActiveBallot InitiativeCalifornia

Hospital Industry's Union-Spending Counter-Measure (#25-0021) Misses November Ballot While SEIU-UHW Clinic Measure Proceeds

Nov 3, 2026(29 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.

FailedBallot InitiativeContra Costa County

Contra Costa's Measure B FAILS (~42%-58%) — a ~$150M/Year County Medicaid-Backfill Tax Rejected by Voters

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.

ActiveCoalition ActionTexas

TACHC Leaders Testify at Texas Capitol on Rural Health Transformation Funding and 340B

Nov 3, 2026(29 days)— Watch for the interim-charge report and any RHTP allocation guidance affecting FQHC eligibility.

ActiveFederal ActionFederal

NACHC Presses Congress for a Multi-Year Community Health Center Fund Reauthorization Before the Dec 31, 2026 Cliff

Dec 11, 2026(67 days)— October 1, 2026: the September 2 stopgap (P.L. 119-103) funds the government through December 11 and does not extend the health center fund or NHSC. Under P.L. 119-75, both are funded only through December 31, 2026. No extension bill has been introduced. Watch the December 11 deadline.

PassedLocal FundingCalifornia

HCAI's Behavioral-Health Recruitment & Retention Program Opens June 1 — FQHCs Eligible for Up to $20K Recruitment + $35K/Yr Supervision + $50K Student Support

Jun 1, 2027(239 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.

In CourtLegal ActionFederal

Full 4th Circuit Grants En Banc Rehearing of West Virginia & Maryland 340B Contract-Pharmacy Rulings — a National Safety-Net Pharmacy Test

Oct 28, 2026(23 days)— Both en banc cases are set for argument on October 27, 2026, at 9:00 a.m. The consolidated West Virginia appeals (PhRMA v. McCuskey, No. 25-1054; AbbVie v. McCuskey, No. 25-1055; Novartis v. McCuskey, No. 25-1056) and the consolidated Maryland appeals (AbbVie v. Brown, Nos. 24-1939, 24-1949 and 24-1978) were each calendared on August 27, 2026, and the Fourth Circuit's published calendar lists an October 27-30 sitting. On August 10, 340B Health, the American Hospital Association, the West Virginia Hospital Association and ASHP filed a supplemental amicus brief in the West Virginia appeals, which the court accepted on August 11. On September 16, the 8th Circuit declined to rehear its own Missouri contract-pharmacy decision en banc; the dissent from that denial cites the Fourth Circuit panel opinion in McCuskey. Calendared dates can move. The argument comes one week after the October 20 hearing on Medicaid work requirements in Massachusetts v. Oz.

FailedLegislationCalifornia

AB 1460 (CA 340B Contract Pharmacy Protection) Clears Assembly, Amended in Senate to Add Reporting

Dead for the 2025-26 session. AB 1460 passed the Assembly 44-6 on May 19, 2025; its last recorded action is 'In committee: Hearing postponed by committee' in Senate Health on July 16, 2025, and it had no action in 2026. August 31, 2026 was the last day for each house to pass bills (Joint Rule 61(b)(17)), so the bill can no longer reach the Governor; the session formally adjourns sine die November 30. California ends the biennium with SB 786's protection of 340B savings from PBM discrimination but no contract-pharmacy protection law. A new bill could be introduced in the 2027-28 session, which convenes December 7.

FailedLegislationCalifornia

Governor vetoes SB 903, the bill to bar unlicensed AI from offering psychotherapy in California

Vetoed by the Governor on September 30, 2026, the last day to act. The bill's history now reads "In Senate. Consideration of Governor's veto pending." SB 903 does not become law. California's AI rules that apply to health centers are AB 3030 (patient disclosure for generative AI messages) and, from January 1, 2027, SB 503 and AB 1979, both signed the same day.

FailedLegislationCalifornia

California's 4-Bill H.R. 1 Mitigation Package Clears Appropriations + Floor Votes — Advocacy Coalition Pushes Cost-Sharing, Retroactive Coverage, Renewal Automation, Transparency

Jan 1, 2028(453 days)— As of October 1, 2026: AB 2161 was signed September 14 and chaptered as Chapter 209, Statutes of 2026. AB 2756 (Ahrens, Medi-Cal vision quality reporting) is now law: the bill history records both “Approved by the Governor” and “Chaptered by Secretary of State — Chapter 309, Statutes of 2026” on September 18, 2026. Of the California bills tracked here, AB 2348 (Medi-Cal ECM and Community Supports) was the last one pending; it was approved and chaptered September 27, 2026 as Chapter 600, Statutes of 2026. Chapter 209 keeps Medi-Cal active for people renewing during a six-month redetermination who meet all other eligibility criteria, until at least the last day of the month in which the 30-day response period ends; requires county notices of the work requirement by regular mail (or electronically, if the person elects) plus at least one other form, such as phone or text; and requires DHCS to consider every other basis of Medi-Cal eligibility before denying coverage. Subdivision (r) lets DHCS defer any change that needs an appropriation not yet made. Earlier: on August 13, AB 2208 (Stefani) and AB 2201 (Boerner) were held on the Senate Appropriations suspense file and SB 1202 (Weber-Pierson) was held in Assembly Appropriations, ending all three for the session. AB 2756 passed the Senate 39-0 on August 20, and the Assembly concurred 78-0 on August 24.

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.

FailedLegislationCalifornia

AB 403, the CHW and promotora Medi-Cal transparency bill, died January 31

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.

In CourtLegal ActionFederal

Three Health Systems Sue CVS/Caremark for ~$250M in Alleged 340B Savings Diversion (Federal RICO) — Precedent Watch for FQHC Clawbacks

Dec 1, 2026(57 days)— Watch for motions to dismiss in late 2026 and any class expansion that could reach FQHCs/340B covered entities.

PassedCoalition ActionCalifornia

SEIU 1021 + AHS Workers Lead Statewide "Fight For Our Health" Rally Day at Capitol — Third Coalition Pressure Point on May Revise

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.

ActiveBallot InitiativeCalifornia

SEIU-UHW 90% Patient-Care Initiative QUALIFIES for Nov 3, 2026 California Ballot

Nov 3, 2026(29 days)— November 3, 2026 statewide vote — watch final title/summary language, voter-guide arguments, court challenges, and campaign spending.

Measure 1986 qualified for the November 3, 2026 statewide ballot after the 131st-day withdrawal deadline passed.

FailedLegislationMinnesota (precedent for California)

Minnesota 340B Hospital Protection Bill DIES on House Floor — PhRMA Lobby Outmaneuvers Senate 42-24 Passage

Bill failed to reach House floor vote before session-end deadline despite Senate passage 42-24

PassedLegislationMinnesota (precedent for California)

Minnesota Becomes First State to Impose 340B Covered-Entity Reporting Requirements — National Template Created

Law passed and signed — first-in-nation 340B covered-entity reporting requirement

ActiveFederal ActionFederal

NACHC June 2-3 Hill Days Target Dec 2026 CHCF Cliff — Registration Closes May 22

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.

FailedCoalition ActionCalifornia

CSAC + CWDA Counties Demand $6.4B from State to Backfill May Revise Cost-Shift

Jan 10, 2027(97 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.

ActiveCoalition ActionCalifornia

Health4All Coalition Mobilizes Against Newsom May Revise $1.1B Additional Immigrant Medi-Cal Cuts

Jan 10, 2027(97 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.

ActiveCoalition ActionFederal

NACHC + ACH Set Aside 340B Differences — Joint Lobby for Health Center Funding Cliff

Dec 11, 2026(67 days)— October 1, 2026: government funding runs to December 11 (P.L. 119-103) and the health center fund ends December 31 (P.L. 119-75). Track whether NACHC and 340B Health stay aligned on S. 5244, the SUSTAIN 340B Act.

ActiveFederal ActionFederal

NACHC Opens Second 2026 In-District Lobby Window — May 24 to June 1

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.

PassedFederal ActionFederal

HHS OCR Issues Interim Final Rule Extending Section 504 / WCAG 2.1 AA Compliance Deadline by One Year

May 11, 2027(218 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. Under docket HHS-OCR-2026-0133 and RIN 0945-AA30, the IFR is the only document HHS has published — there is no final rule, so the IFR is the operative rule. One caution: the widely circulated "comments close July 6, 2026" date is incorrect and does not appear in the rule. The DATES section reads only "Effective date: This IFR is effective May 7, 2026," and the Federal Register record carries no comment-close date; July 6 looks like a standard 60-day period applied incorrectly by others rather than a date HHS set. Operationally, the extended deadlines apply today and do not await further rulemaking, though HHS could still revise them in a subsequent final rule.

ActiveLegislationCalifornia

CA Assembly Democrats Draw 'Line in the Sand' on Safety Net Cuts in 2026-27 Budget Road Map — Bicameral Counter-Position Ahead of May Revise

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).

Pending VoteBallot InitiativeCalifornia

100+ Organizations Formally Join CalChamber 'Affordable California' Coalition (the measure now on the ballot as Prop 45) — Counter-Ballot Mobilization Phase

Nov 3, 2026(29 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.

ActiveCoalition ActionCalifornia

Health Consumer Coalition Releases 'Medi-Cal 2030' Principles — Person-Centered Framework as Counterweight to H.R. 1 Cuts

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.

ActiveCoalition ActionCalifornia

CCALAC + CHC Coalition Issue Public Statement Against May Revision Medi-Cal Cuts and UIS PPS Elimination

Jan 10, 2027(97 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.

In CourtLegal ActionCalifornia

CHA + Community Clinic Employers File Lawsuit to Block SEIU-UHW 90% Patient Care Ballot Measure

Nov 3, 2026(29 days)— RULING ISSUED Aug 7, 2026. 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. UPDATE (docket re-read 2026-09-12): the case is CLOSED at the district court. CourtListener now shows a "Terminate Civil Case" entry dated August 21, 2026 and a last known filing of the same date; the Initial Case Management Conference previously set for September 11 is not shown as held. Reading order #44 in full adds detail our summary lacked: Secretary of State Weber was dismissed on ELEVENTH AMENDMENT immunity, a distinct ground from standing; the claims against the Proponent Defendants failed on RIPENESS as well as standing; and the complaint was dismissed under Rule 12(b)(1) without prejudice, with the court finding that "Leave to amend would be futile." The court expressly acknowledged the health-center harms and held them unripe: "In opposition, Plaintiffs describe in detail the risks posed to community health centers by the Initiative... Because the Initiative is only a proposal, these harms are not imminent or actual." Co-plaintiff Open Door Community Health Centers, a California FQHC in our directory, was found to lack standing because its mitigation steps were "voluntary and self-imposed." UPDATE (docket re-read 2026-09-21): a new entry #46, a TRANSCRIPT ORDER, was docketed September 18, 2026 — the first activity since the case was terminated August 21. A transcript order is a routine precursor to an appeal, since an appellant orders transcripts for the record under FRAP 10(b), but it is not itself an appeal: there is no notice of appeal on the docket, and a CourtListener search for "California Primary Care Association" restricted to the Ninth Circuit returns zero cases. RECAP re-fetched this docket on September 18, which makes the absence more meaningful than it was on September 12, though RECAP mirrors only what someone pulls from PACER, so absence still is not proof. Treat an appeal as plausible and unfiled on the present record. 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. | BACKGROUND: 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. 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.

PassedCoalition ActionCalifornia

FY2026-27 May Revision Advocacy Window Opens — CPCA / Health4All / CCALAC Coordinated Push for FQHC-Friendly Restorations

Jan 10, 2027(97 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, and Proposition 35 appears nowhere in it either — CHA has separately alleged a diversion of Prop 35 funds, so do not cite Prop 35 rate increases as a win until that is reconciled.

PassedLegal ActionFederal

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

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.

ProposedFederal ActionFederal

H.R. 8629 — Bipartisan Bill to Build the FQHC Workforce Pipeline (NHSC Priority, Loan Repayment, CHW & BH Hiring)

Nov 3, 2026(29 days)— Track House Energy & Commerce / Ways & Means committee action; watch companion H.R. 7289.

In CourtLegal ActionCalifornia

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

Nov 3, 2026(29 days)— RULING ISSUED Aug 7, 2026. 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. UPDATE (docket re-read 2026-09-12): the case is CLOSED at the district court. CourtListener now shows a "Terminate Civil Case" entry dated August 21, 2026 and a last known filing of the same date; the Initial Case Management Conference previously set for September 11 is not shown as held. Reading order #44 in full adds detail our summary lacked: Secretary of State Weber was dismissed on ELEVENTH AMENDMENT immunity, a distinct ground from standing; the claims against the Proponent Defendants failed on RIPENESS as well as standing; and the complaint was dismissed under Rule 12(b)(1) without prejudice, with the court finding that "Leave to amend would be futile." The court expressly acknowledged the health-center harms and held them unripe: "In opposition, Plaintiffs describe in detail the risks posed to community health centers by the Initiative... Because the Initiative is only a proposal, these harms are not imminent or actual." Co-plaintiff Open Door Community Health Centers, a California FQHC in our directory, was found to lack standing because its mitigation steps were "voluntary and self-imposed." ⚠️ APPEAL STILL UNCONFIRMED — docket re-read September 21, 2026. RECAP now carries this docket past the September 8 refresh noted earlier: it shows a new entry #46 dated September 18, 2026, described only as "Transcript Order." The case header still reads Date Terminated: Aug. 21, 2026, and no notice of appeal appears on the district docket. Ordering the hearing transcript is commonly a step taken to perfect an appeal, but it is not itself an appeal and can be ordered for other reasons, so this raises the odds without establishing the fact. Appellate RECAP coverage also lags, so "no appeal" remains unconfirmed rather than established. 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. | CASE RECORD: 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). The single consolidated hearing on July 31, 2026 at 10:00 AM (San Francisco) decided 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 were 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. An Initial Case Management Conference had been set for September 11, 2026; the docket does not show it as held, and the case was terminated August 21, 2026. The pressure behind the timing was the Nov 3 ballot and the Secretary of State's ballot-printing clock.

PassedCoalition ActionCalifornia

CPCA Day at the Capitol Convened California CHC Advocates in Sacramento

Event held; current UIS/PPS posture should be checked against signed-budget and DHCS sources.

In CourtLegal ActionNorth Dakota (federal precedent)

Federal Judge Strikes Down North Dakota's 340B Contract-Pharmacy Law — A Cautionary Precedent for CA's AB 1460

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.

Pending VoteBallot InitiativeCalifornia

CalChamber 'Affordable California' (now Prop 45) Files ~1M Signatures for November 2026 Ballot — Counter to SEIU-UHW 90% Spend Initiative

Nov 3, 2026(29 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).

FailedLegislationCalifornia

SB 1422 Placed on Senate Appropriations Suspense File April 20 — UIS Restoration Bill Now At-Risk

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.

ActivePublic StatementFederal

Washington Hospital Association Files Formal Opposition to HRSA 340B Rebate Pilot — Joins AHA, ASHP, NACHC in Coalition Pressure

Nov 15, 2026(41 days)— October 1, 2026: HRSA answered the comments with a narrower pilot (91 FR 48883): Medicare negotiated-price drugs only, all covered entities including FQHCs, effective January 1, 2027. Next: which manufacturer plans HRSA approved, and whether hospital groups sue.

PassedFederal ActionFederal

DOJ Extends ADA Title II 1 Year — But HHS Section 504 May 11 Deadline UNCHANGED (Confusion Risk)

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.

ActiveFederal ActionFederal

AHA Files Formal RFI Opposition to HRSA 340B Rebate Model — Unified FQHC/Hospital Front

In CourtLegal ActionFederal

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

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).

Pending VoteBallot InitiativeCalifornia

April 17 Signature Sample Check: SEIU-UHW 90% and Exec Pay Cap Initiatives at Critical Procedural Gate

Nov 3, 2026(29 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.

ActiveFederal ActionFederal

NACHC Senate Finance Testimony: Reconciliation Would Cut $7B, Close 1 in 5 Health Centers, Displace 7.6M Patients

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.

ActiveLegislationCalifornia

NACHC State 340B Legislation Tracker — 37 States Protect CHC 340B Savings, but Only 21 Have Contract-Pharmacy Provisions; California Has SB 786 but Not a Contract-Pharmacy Law

Nov 3, 2026(29 days)— California's gap is now settled: AB 1460, the state's 340B contract-pharmacy bill, had no action in 2026 (its last recorded action was a postponed hearing on July 16, 2025) and died when August 31, 2026, the last day for each house to pass bills, passed; the session formally adjourns sine die November 30. California ends the biennium with SB 786's PBM non-discrimination protection for 340B savings but no contract-pharmacy law. What to watch: CPCA's 2027 legislative agenda for a new bill.

ActiveCoalition ActionCalifornia

Health4All Coalition Mobilizes Against UIS Adult Dental Cut + $30 Premium — Distinct From SB 1422 Enrollment Defense

Jan 10, 2027(97 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.

ActivePublic StatementCalifornia

Medi-Cal Optometry Rate Has Been ~$47 for 25 Years — California Optometric Association + CalMatters Push for Rate Update

Dec 31, 2026(87 days)— Track DHCS rate review schedule, CA budget cycle vision provisions, COA legislative priorities for 2027 session.

PassedFederal ActionFederal

HRSA 340B Rebate Pilot ICR Comment Window CLOSED April 27 — AHA/ASHP/NACHC/WHA All Filed Formal Opposition

Both comment windows closed; AHA/ASHP/NACHC/WHA filed formal opposition arguing >$1B/year cost

In CourtLegal ActionFederal

PhRMA Sues Washington State Over 340B Contract Pharmacy Law — National Precedent for CA AB 1460 Hinges on Outcome

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.

ActiveFederal ActionFederal

Eli Lilly & Novo Nordisk Activate 340B Claims-Data Mandates — FQHCs Face Operational Compliance Burden

Oct 15, 2026(10 days)— RE-CHECKED 2026-09-03: STILL UNRESOLVED. The American Hospital Association stated on 2026-08-11, verbatim, that “to date, we are unaware of any action HRSA has taken to address these policies.” AHA wrote HRSA on January 26, March 3 and April 27 with no response. The policy has spread — AHA counts eight manufacturers with claims-data requirements as of June 1, 2026. Lilly escalated in a June 1 letter to HRSA reporting roughly 70% covered-entity compliance and giving non-compliant entities five business days before instructing wholesalers to strip 340B pricing. IMPORTANT: no confirmed instance of an entity actually losing 340B pricing has been documented — the record shows threats, and we should not report more than that.

In CourtLegal ActionFederal

AstraZeneca Sues Vermont Over 340B Contract Pharmacy Law — Argues Rebate Pilot Preclusion

Nov 3, 2026(29 days)— RE-CHECKED 2026-09-03: NO CHANGE — no ruling found. ⚠️ Date-trap note for our own record: AstraZeneca’s Vermont suit was reported 2025-11-12, not spring 2026; its hook (that Vermont’s law precludes rebate-pilot participation) makes it read as current. Separately, the AHA tracker’s Vermont entry is PhRMA v. Arel (D. Vt.), “Mixed/Inconclusive,” last action 2025-12-29 — that is the FIRST Vermont suit, not AstraZeneca’s. Do not merge the two.

ActiveFederal ActionFederal

CMS Published the Medicaid Work-Requirements Interim Final Rule (CMS-2454-IFC) on June 1 — Exemption Scope Drives FQHC Patient Impact

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.

PassedCoalition ActionFederal

NACHC In-District Advocacy Week April 14–25 — WINDOW CLOSED, NACHC P&I Forum April 28-29 Up Next

In-district advocacy window concluded April 25, 2026. Engagement metrics pending NACHC P&I Forum reporting.

ActiveCoalition ActionLos Angeles, Orange County

CCALAC + CoalitionOC Hold Joint FQHC Advocacy Summit — Unified Front on H.R. 1 Medi-Cal Cuts

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.

In CourtLegal ActionFederal

AbbVie Sues HRSA to Narrow the 340B 'Patient Definition' — a Direct Escalation of FQHC Audit and Eligibility Exposure

PassedCoalition ActionCalifornia

MAJOR WIN: SEIU 1021 + Alameda Health System Workers Ratify New Contract — Layoff Crisis Resolved

Contract ratified. New CEO + new Director of Labor Relations + new governance model. Wage increases retroactive. Layoffs averted.

PassedCoalition ActionNational

NACHC April 14-25 In-District Advocacy Push — Window Closed, NACHC P&I Forum April 28-29 Next

In-district window concluded April 25, 2026. Engagement metrics pending NACHC P&I Forum reporting.

In CourtLegal ActionFederal

AbbVie Files Landmark 340B Lawsuit — 'Most Consequential Manufacturer Challenge to Date'

WithdrawnBallot InitiativeCalifornia

California Hospital Association Files Counter-Initiative Requiring Union Member Approval for Ballot Spending

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 numbered Proposition 44, nor the billionaire wealth tax. Reported by CalMatters (June 25, 2026), ABC10, and Ballotpedia's certified-measure list (June 26, 2026).

ActiveFederal ActionFederal

CMS opens $100M MAHA ELEVATE model, and FQHCs are eligible for grants

WithdrawnBallot InitiativeCalifornia

SEIU-UHW Submits Signatures for California Executive Pay Cap Ballot Initiative — Second Front Against FQHC Leadership Comp

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.

Pending VoteBallot InitiativeCalifornia

SEIU-UHW Submits 1M+ Signatures (~83% Buffer) for 90% Mission Spend + $450K Exec Pay Cap — Near-Certain November Qualification

Nov 3, 2026(29 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)." 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 news reporting, 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. One note on the numbers: this entry's opposition-funding figures — $28.3M against SEIU-UHW's $17.8M — are an April 11, 2026 snapshot and are no longer current, since the opposition has organized as the named "No On Prop 44" committee sponsored by CPCA Advocates.

FailedCoalition ActionCalifornia

CPCA + No-on-AB-1113 Coalition Mounts Legislative Opposition to SEIU-UHW 90% Mission-Spend Mandate

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.

PassedLegal ActionFederal

D.C. District Court Vacates HRSA's 2013 340B GPO Prohibition Policy — APA Win Weakens HRSA Regulatory Footing

GPO Prohibition vacated; child site registration requirement also vacated. Remanded to HRSA for revised rulemaking.

ActivePublic StatementCalifornia

Health Net Commits $1M to Prepare 4.7M Members for Work Requirements

ActiveBallot InitiativeCalifornia

California Billionaire Tax Act: Proponents' $100B Healthcare Funding Ballot Measure Gains Momentum

Nov 3, 2026(29 days)— RESOLVED — signatures were sufficient. The measure became eligible June 17 and qualified June 25, 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.

In CourtLegal ActionFederal

4th Circuit Blocks West Virginia's 340B Contract Pharmacy Law — First Federal Appeals Win for Drugmakers, Weakens CA AB 1460 Path

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.

In CourtLegal ActionFederal

Novartis and AbbVie Sue Washington Over Its New 340B Contract-Pharmacy Protection Law — a Direct Precedent Watch for California's AB 1460

Preliminary injunction denied June 9, 2026 (Judge Estudillo); SB 5981 took effect June 10, 2026 with $5,000/day penalties. Merits litigation continues.

In CourtLegal ActionFederal (Washington)

AbbVie + Novartis File Federal Lawsuit Against WA 340B Transparency Law — Precedent Risk for CA AB 1460

Dec 15, 2026(71 days)— October 1, 2026: the court denied the manufacturers' preliminary injunction June 9, 2026, and Washington's law took effect. Washington outlets report a Ninth Circuit appeal; the appellate docket has not been read here. Track the appeal.

In CourtLegal ActionFederal

Ninth Circuit Revives False Claims Suit Against AbbVie, Novartis, AstraZeneca, Sanofi for 340B Pricing Fraud

Nov 3, 2026(29 days)— Ninth Circuit No. 24-2180: opinion March 17, 2026; rehearing denied May 28, 2026; remanded to the Central District of California. What to watch: the district court's ruling on the renewed motion to dismiss. California ended the 2026 session with no 340B contract-pharmacy law (AB 1460 died when the August 31 deadline passed), so this case now matters as federal precedent rather than as an input to state legislation.

PassedFederal ActionFederal

EO 14398 FAR Guidance Deadline May 25 — FQHCs Must Review HR Policies for DEI Compliance

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). Neither the EO 14398 guidance nor the law-firm analyses of it mention FQHCs, health centers, HRSA or Section 330. The distinction that decides scope: FAR clauses attach to federal procurement contracts, while Section 330 awards are federal financial assistance governed by 2 CFR Part 200 — which places Section 330 grantees outside FAR 52.222-90, with health centers that hold 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. No public deliverable marks whether agencies completed the July 24, 2026 contract-modification effort — it is an internal agency contracting process with no direct Section 330 consequence.

PassedLegal ActionFederal

Ninth Circuit Rules FQHCs Can Sue Drug Makers for 340B Overcharges Under False Claims Act

Ruling issued March 17 — FCA suits may proceed for 340B overcharges

In CourtLegal ActionCalifornia

NLRB Seeks Forced Union Recognition at Innercare — ALJ Hearing Underway in San Diego

Oct 15, 2026(10 days)— Check for ALJ ruling on forced recognition

FailedLegislationCalifornia

Sen. Durazo Introduces SB 1422 to Reverse the UIS Medi-Cal Enrollment Freeze

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.

PassedLocal FundingSanta Barbara County

SB Neighborhood Clinics Receives $5M Wyatt Family Donation — Largest in History

$5M donation received. Capacity expansion to 28K patients underway.

PassedLocal FundingAlameda County

Alameda Health System Creates $91.7M Working Group — 183 Layoffs Deferred

Oct 31, 2026(26 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.

Pending VoteBallot InitiativeSan Diego County

San Diego County Exploring $360M Community Health Tax Ballot Measure

Nov 3, 2026(29 days)— Measure B is on the November 3, 2026 ballot. If it passes, 17% of revenue goes to County Medical Services, which pays providers for uncompensated care in hospitals and clinics, and 9% to health services Medicaid used to fund. Watch how the County budgets that 17%.

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%) estimated by the County ballot question to raise $400 million to $450 million a year, with no end date 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. The ordinance caps health, food and children's programs at 60% of revenue, including 17% for the County Medical Services program ("provider reimbursements for uncompensated care ... delivered through hospitals, clinics, community providers, or contracted partners") and 9% for affordable health care services; it passes by majority vote and is Measure B on the ballot. 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.

PassedBallot InitiativeLos Angeles County

Measure ER (Essential Services Restoration Act): LA County Half-Cent Health Tax on June 2 Ballot — $1B/Year for Community Health

Jan 15, 2027(102 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.

ActiveFederal ActionFederal

H.R. 7391, the Community Health Center Drug Pricing Protection Act, has 58 cosponsors

Dec 1, 2026(57 days)— October 1, 2026: still in Energy and Commerce with no markup. HRSA's revised rebate pilot starts January 1, 2027 with no FQHC carve-out. Watch for this bill in a year-end health package.

ActiveCoalition ActionCalifornia

CPCA-PCDC Partnership for Expanded Healthcare Access in Underserved Communities

Dec 1, 2026(57 days)— Check partnership progress and outcomes

ActiveFederal ActionFederal

NACHC P&I Forum: $7B Federal Advocacy Push for Community Health Center Funding

Dec 1, 2026(57 days)— Track CHCF reauthorization progress before December expiry

FailedLegislationCalifornia

SB 1422 (Durazo) Clears Senate Appropriations 5-2 (May 14), Now at Senate Third Reading

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.

PassedFederal ActionFederal

HRSA 340B Rebate Model RFI — Comment Deadline April 20 for FQHC Stakeholders

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." Scope note: neither notice names FQHCs, Section 330 grantees or health centers — the covered-entity exposure, paying WAC upfront and waiting on a rebate, follows from the rebate mechanism itself rather than from anything the rule says about health centers. 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.

Signed Into LawLegislationCalifornia

AB 2161 Becomes Law: California Adds Guardrails to Medi-Cal Work-Requirement Verification (Chapter 209)

Jan 1, 2027(88 days)— Watch DHCS implementation guidance and whether any provision is deferred for lack of an appropriation before the requirement can begin, no sooner than January 1, 2027.

Enacted as Chapter 209, Statutes of 2026 (governor's approval recorded September 14, 2026 in the chaptered text; September 15 in the bill history). The law keeps coverage active at least until the last day of the month of the 30-day period after a noncompliance notice for renewing enrollees who otherwise qualify, treats self-attestation of a late notice as good cause, requires counties to confirm conflicting data before adverse action and DHCS to consider every other eligibility basis before denial, and lets DHCS defer provisions that need an appropriation that has not been made.

PassedLegal ActionFederal

Federal Courts Block 340B Rebate Pilot — 1st Circuit Upholds Halt, HRSA Pauses Program

The litigation over the first 340B rebate pilot concluded against HHS: 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. 340B Report reported on July 30 that OMB completed review of a successor "Rebate Pilot 2.0" in late July after reclassifying it as significant. As of July 31, 2026, no Rebate Pilot 2.0 notice had been published in the Federal Register.

PassedLegal ActionFederal

HHS Withdraws 340B Rebate Pilot Appeal — Program Effectively Vacated (FQHC Win)

HHS withdrew appeal; program effectively vacated. Pharma's rebate model dead in current form.

ActiveFederal ActionFederal

AOA Lobbying to Add Optometrists to NHSC Loan Repayment Eligible Disciplines (bill number withdrawn — see correction)

Feb 15, 2027(133 days)— October 1, 2026: no current-Congress bill adding optometrists to NHSC loan repayment was found; H.R. 920, H.R. 1312 and S. 898 are unrelated. Re-check after the 120th Congress convenes. NHSC mandatory funding ends December 31, 2026.

ActiveCoalition ActionCalifornia

70+ Organizations Form 'Save Our Dental Care' Coalition Against $1B Medi-Cal Dental Cut

Jan 10, 2027(97 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.

In CourtLegal ActionFederal

New Mexico's First-in-Nation 340B Contract-Pharmacy Law for Health Centers Takes Effect — PhRMA Sues, 8 Drugmakers Exempt NM Centers

Nov 3, 2026(29 days)— RE-CHECKED 2026-09-03: PhRMA’s preliminary-injunction bid was DENIED and New Mexico’s health-center 340B law was upheld — the AHA state-law tracker records the New Mexico matter as “State Law Upheld” with a most-recent action of 2026-05-26. PhRMA appealed (reported 2026-06-11); summary-judgment motions and notices of supplemental authority were filed in late August. Two date traps to avoid: AbbVie’s second New Mexico suit is dated 2025-12-16, and the ‘eight drugmakers exempt New Mexico health centers’ story is 2026-01-06, tied to the law taking effect January 1 — neither is an August 2026 development.

ActiveCoalition ActionCalifornia

SEIU-Community Clinics Labor Management Partnership: 3,000+ Workers Trained via High-Road Model

PassedLegal ActionFederal

AHA + Maine Hospital Association + 4 Safety-Net Hospitals Sue HHS Over 340B Rebate Model in U.S. District Court for Maine

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.

PassedBallot InitiativeSanta Clara County

Santa Clara County Measure A Passes — $330M/Year Local Health Tax Takes Effect April 1

Tax took effect April 1, 2026. First revenue collection underway.

PassedBallot InitiativeCalifornia

Protect Access to Healthcare (2024): The Coalition Measure That Became Proposition 35

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.

FailedLegal ActionCalifornia

CHCAPA v. DHCS (2020–2022): California Opposed Health Centers' Bid to Halt the Medi-Cal Rx 340B Carve-Out

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.

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