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The move from per-visit PPS toward APMs, capitation, and risk. Find the programs, payment models, deadlines, case studies, resources, and courses that help your team make the shift.
10 programs, 35 resources and courses, and 24 glossary terms. Updated Oct 2, 2026.
5
transition stages
35
resources and courses
5
active programs
Three consequential VBC deadlines land on the same day: ACO REACH sunsets, the CalAIM 1115 + 1915(b) waivers expire, and the current Medi-Cal MCO tax expires. The single most important date on the FQHC VBC calendar.
Five stages from per-visit PPS to full risk, mapped to HCP-LAN APM Framework categories. Select where your center is to see what to build, what to do first, and which resources to use.
Build the foundation and the will
Still paid per-visit, but starting to ask what it would take to get paid for outcomes. The work here is foundational: clean data, an empaneled patient population, PCMH-level care, and leadership that wants to move.
NACHC
3 domains (Infrastructure, Care Delivery, People) → 15 change areas, each scored on a 1 (Learning) to 5 (Expert) maturity scale.
Health Care Payment Learning & Action Network
Category 1 (FFS, no quality link) → 2 (FFS linked to quality) → 3 (APMs on FFS: 3A shared savings, 3B downside risk) → 4 (population-based/capitated: 4A-4C).
Community Care Cooperative
7 Integrated Primary Care domains (engaged leadership, QI, access, BH integration, SUD, SDOH, trauma-informed care) + 3 supporting domains (IT, population health, finance).
Health Management Associates
6 domains: outcomes measurement, board/leadership, data/technology, partnerships, payer engagement, financial alignment.
Start with the Academy courses, then go deeper with external guides, learning collaboratives, and certifications, each with what its source shows.
Free, bilingual, interactive courses with official sources linked — including OKRs, clinic management, HRSA site-visit prep, and billing compliance.
Course catalog · FQHC workforce and leaders
NACHC's May 2026 plain-language staff resource: what value-based care is, why health centers should implement it, the types of value-based payment models, and how centers can succeed — written for the full range of health center staff, not just leadership.
December 2025 survey of health centers' value-based-payment contract participation, strengths, and gaps — the baseline data NACHC uses to set its education and technical-assistance priorities, and a primary source for tracking sector-wide APM adoption.
NACHC's free national learning community built on the Value Transformation Framework (3 domains, 15 change areas). Monthly live forums, 3 pathways (team/org, individual, grab-and-go), and a self-assessment tool. Over half of US health centers are enrolled.
CHCF's free hub for understanding CalAIM — readiness and planning resources, ECM and Community Supports explainers, and guidance on how to get involved.
A free, step-by-step guide to preparing for and operating under the California FQHC APM: care redesign, staffing, competencies, and priorities. The single best starting point for centers considering the APM.
A free self-scoring tool across the 15 VTF change areas (1 = learning → 5 = expert) to benchmark where your center stands and guide transformation priorities.
Free step-by-step playbooks on population health management, models of care, evidence-based care, and FQHC reimbursement quick tips.
Plain-language explainers on PPS, the wrap payment, APMs, and value-based payment fundamentals — ideal for onboarding new staff and board members.
Technical assistance and readiness support for California health centers preparing for or operating under the FQHC APM.
Oral-health value-based care resources, the Dental Dashboard for quality improvement, and on-demand CE courses for FQHC dental teams.
A free issue brief on improving ECM and Community Supports reimbursement by fixing billing processes — practical revenue guidance for CA FQHC finance teams.
Resources, training, and a peer community specifically for community health centers entering value-based care, launched 2025 by the largest FQHC-serving ACO enabler.
A CAHME-award-winning self-paced online certificate teaching population health management through value-based care, with continuing-education credit.
An online course covering value-based care fundamentals and population health, free to audit (paid certificate optional).
Current (May 2025) guide to FQHC payment streams — how to layer professional services, care-management codes, and APMs on top of PPS.
A scaled self-assessment of the competencies an FQHC needs to participate in payment-reform models — the FQHC-specific complement to the VTF assessment.
A financial-readiness and revenue-projection model for FQHCs to test value-based payment and capitation scenarios.
How to structure, staff, and bill a care-management program to meet CMS reimbursement requirements — the engine of VBC performance.
The standardized SDOH risk-assessment tool (25+ languages; ICD-10/LOINC/SNOMED coded) plus a full toolkit for screening and responding to social needs.
How FQHCs bill the new Medicare Advanced Primary Care Management codes (G0556/G0557/G0558) — a key bridge revenue stream into VBC.
Health-IT-focused VBP readiness resources for health centers, including the hosted payment-reform readiness tool.
Profiles four real FQHC value-based payment models (Oregon APCM, Washington APM4, Illinois Medical Home Network, Minnesota FUHN).
A free self-assessment gauging readiness across six domains: outcomes measurement, board/leadership, data/tech, partnerships, payer engagement, and financial alignment.
A maturity-leveled readiness assessment for risk-bearing provider organizations (ACOs, IPAs, clinically integrated networks).
Statewide technical assistance preparing California FQHCs for capitation/APM — site visits, convenings, and coaching.
California's operating capitation-readiness cohort (Comprehensive + Low-Intensity tracks) for FQHC teams making the APM transition.
An FQHC-governed ACO that publishes its Integrated Primary Care VBC journey and a 10-domain capitation-readiness model adapted from NACHC's tool.
A health-value and population-health-management certificate (core courses include Population Health Management Approaches and Community-Engaged Health Improvement).
The full 7-course Coursera specialization on value-based care, with a capstone — the in-depth path beyond the single population-health course.
A two-module finance credential covering the business of health care and operational excellence, including value-based payment models.
The HCC / risk-adjustment coding credential — the documentation-accuracy skill that drives the benchmarks VBC contracts are measured against.
Weekly interviews with value-based care executives and clinicians, with a strong primary-care-transformation catalog.
A physician-led ACO planning guide with model profiles and a calculator to estimate revenue across CMS tracks.
Up-front capital for new low-revenue, rural, or underserved ACOs to fund staffing, infrastructure, and SDOH — a key way to finance the VBC transition.
California's voluntary program letting FQHCs swap PPS per-visit billing for a capitated PMPM equal to their total projected PPS payment entitlement, paid through Managed Care Plans. The goal: free centers from the per-visit treadmill to redesign care (telehealth, group visits, team-based and asynchronous touches). New cohorts onboard each January 1; applications are due roughly 12 months ahead (~Dec 16).
For FQHCs
A major VBC vehicle for California FQHCs. Guardrails: participating centers must maintain ≥70% of historical PPS-eligible visit utilization, and a PPS reconciliation safeguard can pay the difference if PMPM payments fall short, reducing downside exposure compared with less-protected capitation models.
California's Medicaid transformation. ECM provides comprehensive, whole-person care management to high-need members; Community Supports fund non-clinical services (housing navigation, medically tailored meals, sobering centers) as cost-effective substitutes for higher-acuity care. Both run through Managed Care Plans and are core to the FQHC value-based revenue mix.
For FQHCs
ECM ($956M total funds, FY25-26) and Community Supports ($231M) are major FQHC revenue lines. DHCS formally submitted the 1115 renewal to CMS on May 11, 2026 (proposed term Jan 2027 – Dec 2031) and has clarified that ECM AND most Community Supports continue under California's standalone managed-care regulatory authority regardless of waiver approval — so the genuine Dec 2026 cliff exposure is now narrowed to only the services that specifically depend on 1115 authority, not the whole ECM/CS book. A separate 1915(b) managed-care waiver comment window is open May 21 – June 20, 2026.
CMS's permanent Medicare ACO program. BASIC track offers a glide path (including upside-only levels) toward the two-sided ENHANCED track. The most common on-ramp for FQHCs into Medicare value-based care, usually via enablers like Aledade.
For FQHCs
The safest first step into Medicare risk. Note: the CY2026 final rule shortens the BASIC upside-only window from 7 to 5 years (agreements starting Jan 1, 2027) and removes the health equity adjustment from the quality score — pushing FQHCs toward downside risk sooner.
Total-cost-of-care ACO model for Traditional Medicare with two risk tracks (Professional 50% / Global 100%) and primary-care capitation options. Performance Year 2026 is the final year — the model ends December 31, 2026.
For FQHCs
Heavy safety-net participation: 1,042 FQHCs/RHCs/CAHs in 2024 (>25% increase over 2023). Its sunset, with the LEAD successor not starting until Jan 2027, creates a potential gap-year disruption for participating centers. CMS also renamed the 'Health Equity Benchmark Adjustment' to a budget-neutral 'population adjustment.' PY2026 adds a new Substance Access Beneficiary Engagement Incentive for participants.
The official successor to ACO REACH and the longest performance period CMMI has ever set: a 10-year run (Jan 1, 2027 → Dec 31, 2036). RFA opened March 31, 2026; first-cohort application window closed May 17, 2026. Two-sided risk with capitation options. Benchmarks are NOT rebased for the entire decade — fixed historical baseline updated annually by blended national/regional growth factors (a major improvement over MSSP's 5-year rebasing).
For FQHCs
Three structurally important wins for FQHCs vs. ACO REACH: (1) the model's '3%' terms are performance mechanics — a 3% quality withhold ACOs earn back on performance plus a 1.75–3% benchmark discount for Global-risk ACOs — not an FQHC set-aside, so the real FQHC win is structural, not a carve-out; (2) the frozen 10-year benchmark stops the success-punishment treadmill MSSP creates; (3) CMS classifies all FQHC and RHC services as primary care for LEAD, so FQHC/RHC participants (CCNs) are auto-enrolled in the Primary Care Components (PCC) track rather than having to separately argue for primary-care designation the way general acute hospitals do. Current ACO REACH participants get a streamlined 'abbreviated' application. New Entrant minimum: 5,000 beneficiaries; High-Needs ACOs: 1,250. For CA FQHCs the entry gate for PY1 (Jan 1, 2027) is now whether your enabler (C3, MHN, Aledade) applied by May 17 — future cohorts expected with dates not yet announced.
A CMMI model testing prospective, population-based primary care payments within MSSP. Participants get a one-time $250,000 Advanced Shared Savings Payment plus monthly Prospective Primary Care Payments (PPCP) that replace fee-for-service for primary care.
For FQHCs
Includes an explicit FQHC/RHC PPCP enhancement — ACOs with a higher proportion of FQHCs/RHCs see MORE net revenue. Directly advantages FQHC-heavy ACOs. Monitor for early changes given the CMMI strategy refresh.
A 10.5-year multi-payer advanced primary care model across 8 states and the first CMMI model to include FQHCs in a multi-state advanced primary care test (FQHCs got upside-only risk). Terminated early on December 31, 2025 as part of CMMI's March 2025 termination wave.
For FQHCs
Was a major FQHC on-ramp into advanced primary care; its early termination is a notable loss for participating health centers and a signal of the new 'fewer, more rigorous models' direction.
A voluntary advanced primary care payment model (population-based payment plus a flat visit fee and a performance-based adjustment). Ended early December 31, 2025, a year ahead of its scheduled close.
For FQHCs
One of four models CMMI terminated early in 2025 (~$750M projected savings). Its closure narrows the menu of advanced primary care options available to FQHCs entering Medicare VBC.
One of nine new CMS Innovation Center models unveiled in the late-2025 strategy refresh. ACCESS is a technology-supported model for managing chronic conditions at scale. Applications opened January 12, 2026; the model launches July 5, 2026 and runs for roughly a decade (to 2036).
For FQHCs
Primary care practices — including FQHCs — can participate. It opens a fresh chronic-care VBC pathway aligned with the bread-and-butter of health-center work (diabetes, hypertension, behavioral health), and partly backfills the on-ramps lost when MCP and Primary Care First were terminated early.
A new CMS Innovation Center model testing whole-person, lifestyle-medicine interventions inside Original Medicare — functional and lifestyle-based care not currently covered. CMS says its first cohort launches in October 2026. $100M over 3 years, 30 awardees from FQHCs + RHCs + ACOs + health systems + functional/lifestyle medicine practices. FQHCs explicitly eligible.
For FQHCs
Emerging and still uncertain in FQHC fit, but conceptually aligned with the whole-person, prevention-first care FQHCs already deliver. Worth monitoring as a potential reimbursement path for lifestyle-medicine and SDOH-adjacent services.
The traditional FQHC method: a fixed, all-inclusive per-visit rate per Medicaid/Medicare encounter, set per center and inflation-adjusted by the Medicare Economic Index.
For FQHCs: The baseline that VBC moves away from. It rewards visit volume and pays nothing for phone, text, group, or asynchronous care — the very modalities that improve access for working patients.
A fixed per-member-per-month (PMPM) payment for an assigned panel regardless of visit count. California's FQHC APM sets the PMPM equal to a center's projected PPS entitlement, with a PPS-equivalent floor and a ≥70% utilization rule.
For FQHCs: Frees care teams to redesign how they reach patients — telehealth, group visits, CHW outreach, async messaging — without losing revenue. The CA APM's reconciliation floor makes it the lowest-risk capitation entry available to FQHCs.
An ACO keeps a share of the savings it generates versus a spending benchmark, with no penalty if it overspends.
For FQHCs: The safe on-ramp into Medicare value-based care — most FQHCs start here (MSSP BASIC lower levels). It builds the data and care-management muscle needed before taking on downside risk.
An ACO shares in savings AND must repay losses if spending exceeds the benchmark. Higher reward, real financial exposure.
For FQHCs: Requires reserves or reinsurance to absorb potential losses. CMMI's new strategy is pushing all participants toward this — under-capitalized FQHCs should secure downside protection (stop-loss, enabler partnerships) before entering.
A Medicare monthly care-management payment — not a full APM, but value-oriented. The three APCM codes are tiered by patient complexity: G0556, G0557, and G0558 for qualifying Medicare beneficiaries.
For FQHCs: CMS states that FQHCs and RHCs can bill APCM once per patient per calendar month when the billing requirements are met. Report G0556, G0557, or G0558 as applicable. APCM was not included in G0511; CMS directs centers furnishing APCM to report the applicable APCM code. Starting January 1, 2026, optional G0568, G0569, and G0570 add-ons may be reported in the same month as an APCM base code for qualifying CoCM or general BHI services. Verify beneficiary eligibility, consent, applicable service elements, documentation, same-month and base-code rules, distinct-service rules, and current MAC guidance before billing.
Partial risk covers a slice of spending (e.g., the primary care budget); full/global risk covers the total cost of care across all services. The deepest end of the VBC pool.
For FQHCs: Most FQHC value-based care is partial risk. Full risk is the domain of mature operators — AltaMed, for example, takes global risk on its PACE program. Full risk demands sophisticated actuarial, utilization-management, and reserve capabilities.
First cohorts of FQHCs begin capitated PMPM payments in place of PPS per-visit billing.
For APCM furnished on or after January 1, 2025, CMS directs FQHCs/RHCs to report G0556, G0557, or G0558 as applicable because APCM was not included in G0511. The separate transition away from G0511 for other care-coordination services ended after September 30, 2025.
CMMI ends four value-based models early as part of its March 2025 strategy refresh — including the two major advanced primary care on-ramps for FQHCs (MCP and PCF).
Per the Episcopal Health Foundation, the 2025 Texas Legislature directed HHSC to evaluate Medicaid coverage of Diabetes Prevention Program (DPP) services, with findings due in 2026 that could create a sustainable DPP financing path for FQHCs. In parallel, Texas's ~$1.4B (five-year) federal Rural Health Transformation Program expands community-based prevention across rural counties — building VBC-aligned infrastructure FQHCs can use for value-based DPP contracting.
Starting January 1, 2026, CMS requires FQHCs/RHCs to report the individual codes that replaced G0512 and G0071. CMS also adopted G0568, G0569, and G0570 as optional add-on codes when qualifying BHI or CoCM is furnished in the same month as APCM. Payment depends on current code-specific requirements; this is not automatically net-new revenue.
The new CMS-HCC risk-adjustment model reaches full phase-in, cutting average MA risk scores ~3.12% (~$11B savings) and raising documentation specificity demands on risk-bearing providers.
DHCS public comment period (Feb 10 – Mar 12, 2026) on the CalAIM 1115 demonstration renewal concept paper.
DHCS formally submitted the CalAIM 1115 demonstration renewal to CMS, requesting Jan 1, 2027 – Dec 31, 2031. DHCS also confirmed ECM and most Community Supports continue under standalone managed-care authority regardless of waiver approval — materially de-risking the CalAIM leg of the Dec 2026 cliff.
CMS issued a formal completeness determination on DHCS's May 11 CalAIM 1115 renewal submission. Multiple sources (CSAC's May 19 briefing deck, Aurrera Health) converge on CMS/DHCS negotiations running through 2026 with approval expected 'late December 2026' for a Jan 1, 2027 effective date — meaning essentially zero runway between federal approval and the day the current waiver expires. Sharpens the 'triple cliff' framing: this isn't just an expiration date, it's an approval-timing risk with almost no buffer.
Separate 30-day public comment window on the CalAIM 1915(b) managed-care waiver renewal (May 21 – June 20, 2026; comments to 1115Waiver@dhcs.ca.gov). A live advocacy/engagement deadline distinct from the 1115 demonstration.
LAUNCHED as scheduled: a technology-supported chronic-care model — one of CMMI's nine new models — went live July 5, 2026 with nearly 200 first-cohort organizations (AMA). Primary care practices including FQHCs can participate; late applicants start Jan 1, 2027.
On July 7, 2026 CMS released a CMCS Informational Bulletin ending its 'fast-track' review process for certain Medicaid Section 1115 demonstration extensions, formally rescinding the 2015 guidance that implemented the option. The bulletin cites the new statutory requirement (per H.R. 1 and CMS's June 11 SMDL #26-003) that the CMS Chief Actuary certify demonstrations will not increase federal Medicaid spending — a requirement that begins January 1, 2027; the bulletin itself did not include an effective date. Together the two documents reshape the review environment for California's CalAIM 1115 renewal (submitted May 11; current waiver expires December 31, 2026): more actuarial documentation, no expedited extension path.
On July 9, 2026 CMS released PY2024 financial and quality results for ACO REACH: 115 REACH ACOs generated approximately $2.511 billion in gross savings (a 6.7% gross savings rate), with $988.3 million in net savings to CMS (2.6%) and $1.522 billion in net savings to ACOs (4.2%). 96 of 115 ACOs (83%) earned net savings from financial settlement, and 49 met High Performers Pool requirements; the model's 14 High Needs Population ACOs posted the highest net savings rate (14.0%). PY2024 is the model's final full performance year before REACH sunsets December 31, 2026 and the 10-year LEAD Model launches January 1, 2027 — LEAD will also focus on better coordinated care for high-needs patients, such as those dually eligible for Medicare and Medicaid. FQHC-affiliated ACOs in REACH should be planning the LEAD transition now.
CMS's CY2027 Physician Fee Schedule proposed rule (issued by CMS July 14, 2026 and published in the Federal Register July 16, 2026) proposes to continue waiving the in-person visit requirement for mental-health services furnished via telehealth at rural health clinics and federally qualified health centers through December 31, 2027 — preserving a key access flexibility for behavioral-health-integrated FQHCs. The rule also proposes Medicare Shared Savings Program changes (raising the BASIC track Level E shared-savings rate from 50% to 60%). Public comments are due September 14, 2026.
On September 21, 2026 CMS released the names of 79 ACOs (65 Global risk, 14 Professional) in LEAD's optional Implementation Period, which runs September 15 through December 31, 2026. CMS says it is working with well over 100 ACOs preparing for Performance Year 2027 (starts January 1, 2027), and ACOs have until mid-December to finalize. The list is not exhaustive, because ACOs did not have to join the Implementation Period to take part in PY2027.
The ACCESS model page (last modified September 18, 2026) no longer lists an October 1, 2026 start date and now says only that the 10-year model offers rolling start dates. CMS announced on September 15, 2026 that heart failure, COPD, substance use disorder and tobacco cessation tracks start in spring 2027 (April 1, 2027 on the model page), and that 160 organizations participate. The participant list (updated September 15) includes Yakima Valley Farm Workers Clinic, a Washington health center.
CMMI's lifestyle-medicine / whole-person model inside Original Medicare launches its first cohort in October 2026, with award notices in fall 2026, per the CMS model page. Conceptually aligned with FQHC prevention-first care; FQHC fit still emerging.
CMS's Shared Savings Program timeline for a January 1, 2027 start (page modified September 1, 2026) sets Phase 1 Final Disposition for October 20, 2026. Phase 2 submissions (ACO participant lists) run October 21-30, final dispositions arrive December 8, and ACOs sign agreements December 9-16.
California's statewide health care cost-growth target becomes enforceable with the 2026 performance year (3.5%), data collected 2027, public reporting 2028.
Three consequential VBC deadlines land on the same day: ACO REACH ends, the CalAIM 1115 + 1915(b) waivers expire, and the current Medi-Cal MCO tax expires. The single most important date on the FQHC VBC calendar.
ACO REACH's 10-year successor begins, the CalAIM renewal period starts, and a new (smaller) MCO tax takes effect if federally approved.
The prospective primary care payment model with its FQHC/RHC enhancement reaches its scheduled close.
California's target to raise primary care to 15% of total medical expense statewide (from as little as ~7% today) — a structural tailwind for FQHCs.
Aledade, the Community Health Center Association of Mississippi (the state PCA) and Mississippi Health Safe Net (the HCCN) ran a year-long, peer-to-peer blood-pressure collaborative across Mississippi community health centers. (Participant count is unresolved: Aledade materials cite 10 CHCs joining while another passage refers to eight participating health centers — likely attrition, so we do not state a firm number.) Reported in July 2026, it shows how value-based-care infrastructure — shared data via the Azara EHR, structured collaboration, and shared-savings incentives — can move a hard clinical metric in a high-poverty, rural setting.
A UCLA-RAND interim evaluation released May 2026 found CalAIM's Enhanced Care Management (ECM) and Community Supports grew from 82,088 members in early 2022 to 256,406 active members by Q3 2024, with 500,447 ever-served — growth driven in part by PATH infrastructure funding to community-based providers including FQHCs. It is the most authoritative state-evaluation evidence yet that the ECM/Community Supports model scaled, strengthening the case for FQHC investment ahead of the December 2026 CalAIM waiver decision.
A peer-reviewed study (PMC11574694) measuring what happens to preventive-care quality when FQHCs join Medicare Shared Savings Program (MSSP) ACOs found meaningful improvements with no increase in cost: flu vaccination rose +5.9 percentage points, tobacco-use screening +11.8pp, and depression screening +8.9pp relative to controls. It is among the only peer-reviewed evidence directly isolating FQHC quality outcomes inside an MSSP ACO structure — the quality complement to the cost-savings case (Maryland FPCC's 3:1 ROI). Together they form an 'ECM/VBC improves quality AND saves money' evidence package for FQHC boards weighing MSSP entry ahead of the Dec 2026 cliff.
DHCS published the first quantified cost-effectiveness analysis of CalAIM Community Supports: 9 of 12 services already cost-effective within the study period; the remaining 3 are projected cost-effective over longer time horizons. Headline finding: Housing Deposits reduced applicable service costs by 31.6%. The DHCS fact sheet gives FQHC CFOs a state-published, source-of-truth justification for investing in ECM/Community Supports infrastructure ahead of the CalAIM 1115 waiver renewal (Dec 31, 2026 expiry). Pairs with the Maryland FPCC Milbank 3:1 ROI peer-reviewed study to form an 'ECM + CS works' evidence package for board-level investment decisions. Note: existing CLAUDE.md tracks 15 Community Supports (including Transitional Rent mandatory Jan 1 2026); the DHCS fact sheet references 12 — likely pre-Transitional Rent count or a different categorization.
A 3-year peer-reviewed assessment of the Maryland FQHC Primary Care Collaborative (FPCC) — a 7-FQHC consortium operating under a Medicaid alternative payment model — quantifies the strongest published FQHC value-based-care ROI to date. Total infrastructure investment of $4.4M generated $19.4M in cumulative savings for Medicaid beneficiaries (3:1 ROI) alongside 35% reduction in emergency department visits and 11% reduction in hospitalizations. The Milbank Memorial Fund analysis directly rebuts the Penn LDI 'teacup in a roaring sea' framing with hard outcome data showing a small consortium can move utilization meaningfully when the payment model + infrastructure are aligned. Highly transferable to a similar-size CA FQHC group (e.g., a 5-7-clinic East Bay or Central Valley cluster) considering APM participation.
Carina Health Network — a Colorado-based FQHC-governed ACO — supports all 19 Colorado community health centers with data infrastructure, technology, and practice transformation. It achieved $17.6M+ in Medicare savings across ~12,000 attributed beneficiaries via Medicare Shared Savings Program (MSSP) participation. Geographically diversifies the C3 (Massachusetts) FQHC-governed ACO model — proof that the network-of-FQHCs MSSP playbook is replicable in the Mountain West, not just New England. For California Medicare-attributed FQHCs considering MSSP entry, Carina + C3 + Aledade are the three reference architectures: state PCA-anchored network (Carina), multi-state FQHC-governed coop (C3), or partner with a national MSO (Aledade).
FUHN is a nonprofit Medicaid ACO of ~10 Twin Cities FQHCs (~22,000 attributed Medicaid lives) formed under Minnesota's Integrated Health Partnerships (IHP) demonstration. It is a foundational case study in FQHC-network value-based care: a shared ~$1.5M real-time data warehouse pulling EHR + claims + ADT feeds drove care-coordination gains. A third FQHC-network Medicaid-ACO reference point alongside Maryland FPCC (3:1 ROI) and C3 — and the strongest early proof that the 'shared data infrastructure first' thesis produces measurable utilization reductions transferable to similar-size CA FQHC clusters.
C3 is a nonprofit, FQHC-governed accountable care organization that pools community health centers into Medicare risk arrangements across REACH, MSSP, and ACO PC Flex. Effective Jan 1, 2026 it added 10 new health centers (in CA, CO, MA, OR, RI, and WA) to reach 47 FQHCs. In March 2026 it partnered with OCHIN to launch a national Medicare ACO purpose-built for OCHIN Epic health centers — directly lowering the data-and-onboarding barrier for the many California FQHCs already running OCHIN Epic.
Aledade, the largest network of independent primary care in value-based care, runs MSSP ACOs including community-health-center-only ACOs and partners with FQHCs/RHCs. It includes more than 25% of all community health centers participating in MSSP.
The largest independent FQHC network in the US (60+ centers across LA and Orange County, 700,000+ patients/yr, ~465,000 Medi-Cal patients) operates an IPA plus health-plan partnerships and takes global risk on its PACE program (since 1996). It is running a Medicare risk pilot on roughly 2,000 of ~18,000 attributed Medicare lives.
A peer-reviewed study (Journal for Healthcare Quality, 2022) compared health centers applying NACHC's Value Transformation Framework against nonparticipating centers nationally over three years.
A December 2024 Penn LDI analysis frames value-based payment as still 'a teacup in a roaring sea' of FQHC revenue: centers juggle 10–15 funding streams, 70%+ report physician/nurse shortages, and 77% report mental-health provider shortages. Yet FQHCs regularly meet or exceed national benchmarks for hypertension and diabetes control.
AB 2348 does not bridge the December 31, 2026 CalAIM authority gap: the chaptered law sets no January 1, 2027 start date and no July 1, 2027 deadline for DHCS model managed-care coverage standards. What the law does: requires DHCS to maintain policy guides and all-plan letters defining coverage standards for each community support; requires Medi-Cal managed care plans to adopt community supports policies and educate in-network providers; requires quarterly publication of ECM and Community Supports utilization data, to the extent feasible, until January 1, 2032; sets a standard update process under which DHCS posts proposed policy changes for at least two weeks of public input and publicly releases written policy changes no later than six months before their effective date, with effective dates designated January 1 or July 1; and requires DHCS, by March 31, 2029, to give the Legislature the information needed to consider transitioning community supports into required Medi-Cal benefits, drawing on the final community supports evaluation due to CMS by December 31, 2028. Status: approved by the Governor and chaptered by the Secretary of State as Chapter 600, Statutes of 2026, on September 27, 2026. Enactment still does not supply 2027 authority, so a health center should not budget 2027 revenue as if it did.
Approved by the Governor; chaptered by Secretary of State — Chapter 600, Statutes of 2026 (September 27, 2026)
Effective January 1, 2026, CMS says FQHCs and RHCs can bill care-coordination services established under the PFS when CMS designates them as care-management services. The payable codes appear in the annual Designated Care Management Services table. This policy improves alignment, but it does not make every new PFS code payable to a health center; verify the current table and all code-specific requirements before billing.
Final rule policy effective January 1, 2026
The current CMS Claims Processing Manual extends temporary non-behavioral distant-site telehealth authority for FQHCs/RHCs through December 31, 2027, including audio-only services, using G2025. Behavioral telehealth follows separate visit-billing rules. The extension preserves an access option; it does not by itself establish that a contact satisfies APCM or BHI elements, is separately payable in addition to another service, or generates shared savings. Verify the beneficiary, service, modality, consent, documentation, code, distinct-service, and current MAC requirements before billing.
Signed Feb 3, 2026; flexibilities run through Dec 31, 2027
CMS adopted optional G0568, G0569, and G0570 add-on codes for FQHC/RHC qualifying BHI or CoCM services when an APCM base code is reported in the same month. CMS pays the associated care-coordination add-ons at the national non-facility PFS rate. This is not automatic revenue: verify beneficiary, base-code, service, consent, documentation, and current MAC requirements.
Effective January 1, 2026
Starting January 1, 2026, CMS directs FQHCs/RHCs to report the applicable individual codes instead of G0512 for psychiatric CoCM or G0071 for communication-technology and remote-evaluation services. This is a coding change, not evidence that every underlying service is covered or payable in every circumstance. Verify the current code-specific service, documentation, and billing requirements.
Effective January 1, 2026
CMS states that FQHCs and RHCs can bill APCM once per patient per calendar month when the billing requirements are met. Report G0556, G0557, or G0558 as applicable. The policy took effect January 1, 2025; APCM was not included in G0511, so CMS directs centers furnishing APCM to report the applicable APCM code.
Effective January 1, 2025 for APCM
Shortens the BASIC track upside-only window from 7 to 5 years (agreements starting Jan 1, 2027), removes the health equity adjustment from the quality score (PY2026), removes the SDOH screening measure, and adds a cyberattack EUC exception.
Finalized October 31, 2025
The new Medicare Advantage risk-adjustment model phases in to 100% for payment year 2026, cutting average risk scores ~3.12% (~$11B savings) and demanding more documentation specificity from risk-bearing providers.
Fully phased in PY2026
California's statewide cost-growth target (3.5% for 2025-26, stepping to 3.0% by 2029) plus a primary-care investment benchmark targeting 15% of total medical expense by 2034 (from ~7% today). Beyond the 2034 endpoint, an enforceable annual improvement benchmark of 0.5–1.0 percentage points per year applies for performance years 2025–2033, reported across four market segments (commercial HMO/POS, commercial PPO/EPO, Medicare Advantage, and Medi-Cal). OHCA's first primary-care spending report — the first hard baseline of how far below 15% California actually sits — is due Summer 2026 (data collection began Fall 2025).
Benchmark board-approved Oct 2024; annual improvement benchmark PY2025-2033; first spending report due Summer 2026
The current Medi-Cal MCO tax expires end of 2026. The 2026-27 May Revision proposed a new (smaller) MCO tax effective Jan 1, 2027 — constrained by H.R. 1 and Prop 35 — to fund Medi-Cal provider rate increases that underpin VBC economics. Needs federal approval. UPDATE (June 30, 2026): the signed 2026-27 budget preserved the MCO-tax renewal — the Senate dropped its rival 'Fair Share' per-employee corporate fee in favor of the tax — and CMS's Jan 29, 2026 final rule lets California's current tax run through the end of 2026, resolving the feared June 30 transition cliff. The remaining watch item is CMS approval of the 2027 structure.
Preserved in signed 2026-27 budget (MCO-tax renewal over employer-fee alternative); CMS approval still needed for 2027 structure
Would direct CMS to create hybrid primary-care payments (PMPM at 40–70% of expected FFS charges) and cut beneficiary cost-sharing 50%. Introduced and referred to Senate Finance in the 118th Congress; re-introduction in the current Congress is unconfirmed.
Referred to Senate Finance (118th Congress)
California's FY2026-27 May Revision proposes refining ECM eligibility, service definitions, and payment adjustments plus Community Supports referral pathways, saving $116M total funds ($68.3M General Fund) in 2026-27 effective January 1, 2027. The cut targets the very programs driving FQHC ECM/Community Supports workforce demand — a direct downside tension for health-center-based providers building VBC capacity, and a counterweight to the AB 2348 continuation effort.
A June 2026 AJMC analysis warns CMS underpredicted 2024-2025 Medicare cost growth by ~9-10%, triggering Retrospective Trend Adjustment (RTA) risk corridors that could require REACH ACOs to remit an additional 3-4% of gross savings at PY2025 settlement — on top of the existing CMS discount — potentially erasing net gains for FQHC participants as the model winds down ahead of the LEAD transition in 2027.
H.R. 1's Medicaid cuts and work requirements directly undercut the economics of value-based care for FQHCs: as Medicaid enrollment shrinks, so does the attributed panel behind every PMPM, shared-savings benchmark, and ECM/Community Supports caseload. NACHC estimates ~$7B/year in higher uncompensated-care and operational costs for health centers, and the Commonwealth Fund projects 5.6M CHC patients could lose coverage under work requirements (~$32B in lost revenue over five years). Michigan's PCA alone pegs its state exposure at $94M/year — the clearest signal yet that the safety net's VBC upside is being hollowed out from the enrollment side.
Making Care Primary (FQHCs' first multi-state advanced primary care model) and Primary Care First were killed Dec 31, 2025. Four models terminated, one reduced, two canceled — narrowing the menu of safe FQHC entry points.
ACO REACH (1,042 FQHCs/RHCs/CAHs in 2024) ends Dec 2026, but the LEAD successor doesn't start until Jan 2027 — a possible disruption for centers mid-transition.
CMMI's new strategy prioritizes provider-borne downside risk and signals more mandatory models. Under-capitalized FQHCs could be pushed into risk they cannot absorb.
MSSP removes the health equity adjustment from the quality score (PY2026) and drops the SDOH screening measure; ACO REACH renamed its equity adjustment to a budget-neutral 'population adjustment' — fewer protections for safety-net providers.
The CalAIM 1115 waiver expires Dec 31, 2026, but the threat has narrowed: DHCS submitted the renewal to CMS on May 11, 2026 and confirmed ECM and most Community Supports continue under standalone managed-care authority regardless of waiver approval. Residual risk is limited to the specific services that depend on 1115 authority plus whatever conditions/cuts CMS attaches to the renewal — watch the CMS approval and the 1915(b) comment window (closes June 20, 2026).
'A teacup in a roaring sea' — FQHCs juggle 10–15 funding streams amid workforce shortages (70%+ MD/RN, 77% behavioral health) and stagnant, non-inflation-updated PPS rates, limiting the bandwidth to invest in VBC transformation.
The vocabulary of the transition — every definition with its primary source.
The Medicaid FQHC payment method: a fixed per-visit (per-encounter) rate based on a center's historical costs, trended annually by the Medicare Economic Index.
CMSA supplemental payment a state makes to reconcile what a managed care plan pays an FQHC up to the center's full PPS per-visit entitlement.
MACPACA fixed payment per member per month for a defined set of services regardless of utilization, shifting financial risk to the provider.
DHCSA payment approach that ties payment to value/outcomes rather than straight fee-for-service; California's FQHC APM pays a clinic-specific PMPM equal to projected PPS.
DHCSPayment that holds providers accountable for the quality and total cost of care rather than the volume of services.
NACHCA group of providers who voluntarily join to coordinate care for a defined population and share accountability for its quality and cost.
CMSMedicare's permanent ACO program; ACOs that beat a spending benchmark while meeting quality standards share in the savings (and, in two-sided tracks, the losses).
CMSA CMS Innovation Center capitated/risk-bearing ACO model with a health-equity focus — ending Dec 31, 2026 and succeeded by the LEAD Model (2027).
CMS Innovation CenterAn arrangement where the provider shares in savings but must also repay the payer a portion of spending above the benchmark.
AledadeAn arrangement where the provider shares in savings if it beats the benchmark but owes nothing if spending runs over.
AledadeThe full cost of all care for an attributed population over a period; accountability for TCOC increases as models move toward HCP-LAN Category 4.
HCP-LANThe method that assigns each patient to a provider or ACO (e.g., by where they get most primary care) so that population's cost and quality count for that provider.
CMSThe target spending amount an ACO is measured against; spending below it (with quality met) generates shared savings, above it can generate losses.
CMSCMS's Hierarchical Condition Category model that adjusts benchmarks for how sick a population is, producing a Risk Adjustment Factor (RAF) where 1.0 is average.
HHS OIGThe 2024 CMS-HCC risk-adjustment model (fully phased in for 2026), which remapped ICD-10 codes, raised the HCC count from 86 to 115, and lowered RAF for many conditions.
HHS OIGA monthly, population-based payment for primary care that replaces fee-for-service for those services (used in ACO Primary Care Flex).
CMS Innovation CenterA Medicare monthly care-management service, tiered by complexity through G0556, G0557, and G0558. CMS states that FQHCs and RHCs can bill APCM once per patient per calendar month when the billing requirements are met.
CMSCalifornia Medi-Cal's whole-person, community-based care-management benefit for the highest-need managed-care members — 7 core service components, billed PMPM through plans.
DHCSCalifornia Medi-Cal's menu of 15 pre-approved services (Transitional Rent mandatory as of Jan 1, 2026) that plans may offer as cost-effective substitutes for higher-cost care.
DHCSCalifornia Advancing and Innovating Medi-Cal — DHCS's multi-year initiative of delivery-system, program, and payment reforms, including ECM and Community Supports.
DHCSCalifornia's target requiring payers to raise primary care spending to 15% of total medical expense by 2034 (≈0.5-1.0 percentage points per year).
HCAIA four-category taxonomy: Cat 1 = FFS (no quality link); Cat 2 = FFS linked to quality; Cat 3 = APMs on FFS (3A shared savings, 3B downside risk); Cat 4 = population-based/prospective.
HCP-LANHRSA's standardized annual reporting set for FQHCs, including clinical quality measures (e.g., blood-pressure control, diabetes HbA1c) aligned with HEDIS.
HRSANCQA's Healthcare Effectiveness Data and Information Set — the health-plan performance measure set (90+ measures) used by 90%+ of U.S. plans and often anchoring VBC contracts.
NCQAOur analysis is not legal, medical, financial, tax, or regulatory advice. Read the original source and talk to a qualified professional before you act.