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A California-specific scope-of-practice guide for FQHC executives. Understand what each role can and cannot do under California law, the barriers keeping your team from working at the top of their license, and the revenue impact of getting delegation right.
Last updated: 2026-02-28
For educational purposes only. The regulations, Business & Professions Code citations, and delegation rules presented here are AI-generated summaries — they do not constitute legal advice. Always consult a healthcare attorney or relevant licensing board before making staffing decisions.
10
Roles Mapped
15
Delegation Matrix
CA
Regulatory Citations
PPS
Revenue Impact
Click any cell to see the California regulatory citation. Filter by department to focus your analysis.
Click any cell to see the regulatory citation and FQHC context
| Task | MD/DOPhysician | NPNurse | PAPhysician | RNRegistered | LVNLicensed | MAMedical | CHWCommunity | LCSWLicensed | AMFT/ASWAssociate | RDHRegistered |
|---|---|---|---|---|---|---|---|---|---|---|
| Patient Assessment / Intake | ||||||||||
| Vital Signs | ||||||||||
| Medication Administration (Oral) | ||||||||||
| Medication Administration (Injection) | ||||||||||
| IV Therapy | ||||||||||
| Patient Education | ||||||||||
| Care Plan Creation | ||||||||||
| Triage | ||||||||||
| Prescribing Medications | ||||||||||
| Ordering Labs / Imaging | ||||||||||
| SDOH Screening | ||||||||||
| Psychotherapy | ||||||||||
| Crisis Intervention | ||||||||||
| Dental Prophylaxis (Cleanings) | ||||||||||
| Dental X-rays |
Tap any role to see the full scope, top-of-license barriers, change management strategies, and revenue impact.
31 barriers identified across 10 roles. Most come down to: missing standing orders, outdated supervision agreements, and tasks assigned below training level.
Every role not working at the top of their license is lost revenue. Here is the financial impact of getting delegation right.
Physician visits generate the highest PPS encounter rate. Every physician encounter shifted from below-license tasks to patient-facing visits can generate $200-400+ per visit. FQHCs that optimize physician delegation typically see 15-25% increases in daily patient encounters per physician.
NP visits are billed at the same PPS encounter rate as physician visits in FQHCs — no revenue reduction. NP salary is typically 60-75% of physician salary, meaning each NP-run panel has a significantly higher revenue-to-cost ratio. FQHCs can expand access by adding NP panels at lower cost than physician panels.
PA visits generate the same PPS encounter rate as physician and NP visits in FQHCs. PA salary is typically similar to NP salary (60-75% of physician salary). Expanding PA scope through broader practice agreements increases encounter volume without adding providers.
RN-led visits can generate billable encounters under FQHC PPS when they involve assessment, education, or care management — especially for chronic disease management and transitional care management (TCM). RN care coordination also improves quality metrics that affect grant funding and value-based payment bonuses.
LVN time doesn't directly generate encounters, but enables provider efficiency. LVNs who handle medication administration, wound care, and specimen collection free up RNs for billable activities and allow providers to see more patients per session. Proper LVN utilization typically increases clinic throughput by 10-15%.
MA time doesn't generate direct encounter revenue, but it's the biggest lever for increasing provider productivity. Every task an MA handles before the provider enters the room shortens the visit and allows the provider to see more patients. FQHCs that implement MA-driven pre-visit planning typically see 3-5 additional encounters per provider per day — at $200-400+ PPS rate each, that's $600-2,000+ in additional daily revenue per provider.
Under CalAIM, CHW services are billable through ECM and Community Supports managed care contracts. FQHCs with CalAIM contracts can bill for CHW care coordination, SDOH screening, and navigation services. CHWs also improve patient engagement metrics (show rates, panel retention) that drive overall encounter volume. The ROI of CHW programs is estimated at $2.47 returned for every $1 invested (Penn Center for CHW).
LCSW visits generate a separate FQHC PPS encounter rate — including on the same day as a medical visit. This same-day billing is a significant revenue opportunity: every warm handoff that results in a same-day BH visit generates an additional $150-250+ encounter. FQHCs that implement BHI with same-day billing typically see 15-30% increases in per-patient revenue.
Associate visits are billable at the same PPS encounter rate as licensed clinician visits in FQHCs — no revenue reduction. With associate salaries 30-40% lower than LCSW/LMFT salaries, the revenue-to-cost ratio is significantly higher. A single associate generating 6-8 encounters/day at $150-250+ PPS rate produces $900-2,000+/day in revenue against a salary cost of $55,000-70,000/year. The only additional cost is supervisor time.
Dental hygienist visits generate the FQHC dental PPS encounter rate — a separate billable encounter from medical visits. RDHAPs working in community settings generate encounters that would otherwise not exist (patients who never come to the clinic). The Virtual Dental Home model has demonstrated 30-50% increases in dental encounter volume for FQHCs that deploy community-based hygienists. Dental sealant programs in schools are particularly high-ROI.
Use our Executive Guides to diagnose scope-of-practice challenges and our OKR Templates to set measurable delegation objectives across the organization.