What's new

CMS published the final GLOBE Model rule on October 2, 2026, a mandatory Medicare Part B drug rebate test that takes effect November 30. Claims billed with the 340B modifier are left out of GLOBE rebates, and CMS says the model may indirectly move 340B ceiling prices. The first performance year begins April 1, 2027.

CMS / Federal Register 2026-20281

DHCS dated a member letter October 1, 2026, telling refugees, asylees, parolees and other affected immigrants they keep full-scope Medi-Cal as federal funding ends. They must update immigration information by December 1 and move to fee-for-service Medi-Cal on January 1, 2027. Counties add the letter to new applications starting October 1.

California Department of Health Care Services (MEDIL I 26-21)

HRSA posted approved 340B rebate plans from ten drugmakers, covering 21 drugs such as Eliquis and Jardiance, on October 1, 2026. Rebates start January 1, 2027, and Merck, Pfizer and AstraZeneca apply them to every covered entity type. Sites send claims to the Beacon platform within 45 days, and drugmakers must pay or deny within 10 days.

HRSA Office of Pharmacy Affairs

Governor Newsom signed SB 1099 on September 30, 2026, as Chapter 1009. It states that counties, cities and hospital districts may provide health care and other public benefits to people who would qualify but for a federal immigration-status bar. Each local government decides at its own discretion, and the bill carries no appropriation.

California Legislative Information (SB 1099, Chapter 1009, Statutes of 2026)

More than 281,000 immigrants in nine states and D.C. were expected to lose Medicaid starting October 1, as KFF Health News reported on September 30, 2026. Florida alone counted nearly 177,000. Green card holders, people under 19 and immigrants from Cuba, Haiti and some Pacific Island countries keep their coverage.

KFF Health News

On September 29, 2026, Los Angeles County's chief executive told supervisors that an August lawsuit forces all Measure ER revenue into escrow until the case ends. The final budget counts no Measure ER money this year, and LA Health Services will use $784.5 million in reserves. Clinics expecting Measure ER contracts should plan without that money for now.

County of Los Angeles Chief Executive Office, FY 2026-27 Supplemental Budget board letter (September 29, 2026)

On September 29, 2026, the HHS Office for Civil Rights explained when 42 CFR Part 2 lets state Medicaid agencies use substance use disorder records. States may use them to verify who is excluded from the 80-hour monthly work requirement, such as people in certain treatment programs. Health centers with Part 2 programs can read the FAQ now.

U.S. Department of Health and Human Services, Office for Civil Rights

DHCS posted a provider notice September 29, 2026, opening a new web page for the move of UIS members from managed care to fee-for-service. Providers that bill only through managed care cannot keep caring for UIS members after December 31, 2026. Health centers should update PAVE enrollment and review treatment authorization rules now.

Medi-Cal Providers (California Department of Health Care Services)

Doctors, nurse practitioners and therapists at LifeLong Medical Care, an East Bay health center, held a one-day strike on September 28, 2026, as Berkeleyside reported. LifeLong offered a 6.38% raise over three years, while the Union of American Physicians and Dentists sought a double-digit raise. Other Bay Area health centers may face similar pay and workload demands.

Berkeleyside / Richmondside (September 28, 2026)

Santa Clara County's Valley Health Center San Jose-Campbell opens September 28, 2026, as San José Spotlight reported, with primary, urgent, dental, OB-GYN and behavioral health care. The county bought the 10-story site for $340 million and says its clinics see 1.3 million patients a year. It adds county capacity for low-income and uninsured patients.

San José Spotlight (Joyce Chu, September 23, 2026)

CalMatters reported on September 28, 2026 that Democrat Xavier Becerra promises to keep covering every Californian hit by federal Medicaid cuts but has not said how he would pay. Republican Steve Hilton would replace part of Medi-Cal for the lowest-income enrollees with health spending accounts of $8,000 to $10,000 a year, keeping emergency coverage.

CalMatters

Governor Newsom signed AB 96 by Assemblymember Corey Jackson on September 27, 2026, as Chapter 497. Applicants for Medi-Cal peer support specialist certification no longer need a high school diploma or equivalent, but must still be at least 18. The change widens the pool of certified peer staff that clinics can hire.

California Legislative Information (AB 96, Chapter 497, Statutes of 2026)

Governor Newsom signed AB 1811 by Assemblymember Chris Rogers on September 27, 2026, as Chapter 549. Until January 1, 2035, state programs count an area as a health professional shortage area if the federal government listed it on January 1, 2025, even if that listing later ends. HCAI can also name shortage areas and revoke those designations.

California Legislative Information (AB 1811, Chapter 549, Statutes of 2026)

Governor Newsom vetoed AB 2571 by Assemblymember Heath Flora on September 27, 2026. The bill would have set Medi-Cal pay for advanced practice pharmacist services at 85% or more of the physician fee schedule and sought federal approval to count pharmacists as FQHC and RHC providers. His veto message cites millions in ongoing costs missing from this year's budget.

Office of the Governor of California

Governor Newsom signed SB 1323 by Senator Susan Rubio on September 27, 2026. Health care provider entities must post a notice at main public entrances that immigration agents need a judicial warrant to enter nonpublic areas, and must set visitor procedures. The changes repeal on January 1, 2030.

Office of the Governor of California

Governor Newsom signed AB 2348 by Assemblymember Mia Bonta on September 27, 2026. DHCS must publish model coverage standards for each Community Support and post ECM and Community Supports use data quarterly until January 1, 2032. By March 31, 2029, DHCS must give lawmakers what they need to weigh making Community Supports required Medi-Cal benefits.

Office of the Governor of California

SAMHSA announced $247.9 million in grants on September 25, 2026, for addiction treatment, overdose prevention and mental health services. The largest pieces are $69.4 million to widen access to medications for opioid use disorder and $54.9 million for school mental health through Project AWARE. Health centers that offer this treatment can ask local grantees about referral partnerships.

Substance Abuse and Mental Health Services Administration (SAMHSA)

On September 25, 2026, HRSA announced $89.3 million through the Rural Communities Opioid Response Program for rural communities in 45 states and one territory. The largest piece is $62.7 million for RCORP-Impact to expand substance use disorder treatment and recovery services. Rural health centers can check the award lists for local network partners.

Health Resources and Services Administration

On September 25, 2026, CMS launched Investing in Health Outcomes, with 37 states signing a voluntary Medicaid Quality Pledge. A May 2026 CMS review found about 450 reporting requirements covering roughly 260 quality measures in managed care. States will use the pledge to set outcome targets in quality strategies and upcoming procurements.

Centers for Medicare & Medicaid Services

On September 25, 2026, CMS said Basic Health Program payments will stop counting many lawfully present immigrants starting January 1, 2027. Permanent residents, Cuban and Haitian entrants and COFA migrants still count. CMS will not act against states that stop covering the others from 2027 through 2029.

CMS Center for Medicaid and CHIP Services (Informational Bulletin)

KFF's enrollment tracker, updated September 25, 2026, shows Medicaid enrollment fell by 5.1 million, or 6%, from June 2025 to June 2026. Total Medicaid and CHIP enrollment dropped in 49 states and DC, from a gain under 1% in Iowa to a 19% drop in Indiana, leaving 73.2 million people enrolled.

KFF (Medicaid/CHIP Monthly Enrollment Tracker)

On September 24, 2026, AltaMed released patient data showing depression up 36% and anxiety up 22% among people treated within five miles of the Boyle Heights Lineage warehouse fire, as LAist reported. The comparison covers about 40,000 patients since June 17 against the same period in 2025. Respiratory diagnoses rose 19.9% and eye and throat irritation 24.2%.

LAist (Boyle Heights Beat / The LA Local, September 25, 2026)

On September 24, 2026, Stateline reported on a Health Affairs analysis of new federal limits on state-directed payments. It estimates three dozen states must cut annual Medicaid payments to providers by more than $50 billion, as rates step down 10 points a year from 2028. The author expects hospitals to limit how many Medicaid patients they see.

Stateline (reporting Debra J. Lipson, Health Affairs 45(9), doi 10.1377/hlthaff.2026.00116)

On September 24, 2026, GW's Geiger Gibson Program published a review of more than 120 public comments on CMS's Medicaid community-engagement rule. Commenters said documenting medical frailty pulls clinician time from patient care. They also said health centers will carry much of the cost as patients lose coverage and uncompensated care grows.

Geiger Gibson Program in Community Health, George Washington University (Data Note, Maddie Krips)

On September 24, 2026, CMS asked for input on the standard contract terms Part D plans must offer any qualifying pharmacy starting in plan year 2029. Comments are due November 23, 2026, and CMS asks how plans handle contract terms and claims for 340B patients.

Federal Register / CMS

A HRSA notice published in the Federal Register on September 24, 2026 (91 FR 60626) extends, with funds, the current period of performance for the 272 health centers that must re-compete for their service areas in the fiscal year 2027 Service Area Competition. Centers whose period ends December 31, 2026 (83 awards) or January 31, 2027 (109 awards) are extended through June 30, 2027; centers whose period ends February 28, 2027 (80 awards) are extended through July 31, 2027. The notice lists 272 non-competitive Section 330 awards totaling approximately $527 million (the table sums to $526,899,978) under Assistance Listing 93.224. HRSA states the purpose as avoiding a gap in services while it makes new awards for those service areas. California has the most recipients: 43 health centers with estimated extension awards of $82,493,316, among them AltaMed, United Health Centers of the San Joaquin Valley, St. John's Community Health, Neighborhood Healthcare and Vista Community Clinic. Texas has 5 recipients totaling $10,542,281. Boundary: this is a bridge, not a renewal. Every listed center must still apply through the FY2027 Service Area Competition, and the extension does not change any application deadline.

HRSA / Federal Register notice 2026-19578 (91 FR 60626, Sept. 24, 2026)

Shasta County's health and human services agency closed its eligibility office at 1400 California Street in Redding on September 23, 2026, as Shasta Scout reported. It is the third such office to close in recent years, and no replacement site or date has been named. Patients can still renew Medi-Cal at four other offices or on BenefitsCal.

Shasta Scout, relaying a Shasta County HHSA press release (September 21, 2026)

On September 23, 2026, HHS announced $51 million to 28 health centers to improve dental care for children with neurodevelopmental disorders, including autism and Down syndrome. Each recipient gets up to $2 million through HRSA's new Quality Improvement Fund and joins shared learning and evaluation work.

U.S. Department of Health and Human Services (HRSA)

At a September 22, 2026 district board meeting, Watsonville Community Hospital's CEO said it may close in six to 12 months without financial change, as the Pajaronian reported. The hospital lost $22.4 million in 2025 and may close its NICU and women's and children's services. Pajaro Valley health centers should plan for longer transfers for births.

The Pajaronian (Syd Fluker, September 24, 2026)

CMS said on September 22, 2026 that it canceled about 315,000 federal Marketplace enrollments covering more than 760,000 people as unauthorized. The cancellations took effect August 31, and CMS expects about $2.2 billion in subsidies returned. Health centers in HealthCare.gov states can check patients' coverage at the next visit and help them reapply.

Centers for Medicare & Medicaid Services (fact sheet)

On September 21, 2026, CMS listed 79 ACOs in the LEAD Model's optional implementation period, which runs September 15 through December 31. CMS says it is working with well over 100 ACOs for 2027, and ACOs have until mid-December to finalize. Health centers in an ACO can ask now whether it plans to join LEAD.

CMS Innovation Center

The public comment period on CMS-2452-P, the proposed rule implementing the provider-tax limits in Public Law 119-21 section 71115 (91 FR 46562, published July 23, 2026), closed at 11:59 p.m. Eastern on September 21, 2026. The Regulations.gov record for docket CMS-2026-2476 shows the document is no longer open for comment, and the Federal Register lists no extension notice and no final rule for the regulation (RIN 0938-AV93) as of September 24. The Federal Register's September 24 check of Regulations.gov counted 245 posted comments. What does not change: the class-specific July 4, 2025 ceilings and the expansion-state phase-down are already law and take effect on the statutory schedule whatever the final rule says. The comment period only governs CMS's proposed calculation, reporting, 75/75-test and oversight mechanics.

Regulations.gov docket CMS-2026-2476 / Federal Register (CMS-2452-P, RIN 0938-AV93)

The Governor approved AB 1307 (Ávila Farías) on September 20, 2026 and the Secretary of State chaptered it the same day as Chapter 363, Statutes of 2026. The law repeals the old Licensed Dentists from Mexico Pilot Program and replaces it with a new one: the Dental Board of California "shall accept 30 participating dentists" and issue each a three-year nonrenewable license to practice dentistry, with an alternate list behind them. The employment restriction is the part health centers should read. The chaptered text says "A participant may only be employed by a federally qualified health center that meets all of the following conditions" — the center must have at least one health professional shortage area or dental professional shortage area in its service area as determined by HCAI, must have dental quality assurance protocols, and must be accredited by The Joint Commission, the Accreditation Association for Ambulatory Health Care, or NCQA (or be affiliated with an FQHC that is). Employing centers take on named duties: continue federal peer review, and work with a CODA-accredited California dental school to conduct "10 secondary peer reviews of randomly selected patient encounters with each participant per six-month period." Boundary: the statute sets no rate and makes no prospective payment claim. It requires that participants' services be reimbursable under Medicare, Medi-Cal fee-for-service, Medi-Cal managed care and private insurance, but it says nothing about what an FQHC is paid. Timing is genuinely open — the text funds the program and its evaluation entirely from philanthropic foundations and says the Board should implement "within six months of receiving an amount of philanthropic funds," and no funder is named, so there is no start date to plan around yet.

California Legislative Information

The California Primary Care Association and five clinics sued SEIU-UHW and its president, Dave Regan, in federal court on September 18, 2026, as the Los Angeles Times reported. The racketeering suit says the union offered to drop Proposition 44 if clinics backed union elections for 25,000 workers. Regan has denied that trade, and voters decide Proposition 44 on November 3.

Los Angeles Times (Taryn Luna), via Yahoo News

The Justice Department revised its Justice Manual on September 18, 2026, so False Claims Act cases rest only on binding statutes, regulations or contracts. The change revives a 2017 policy and tells its lawyers to weigh dismissing whistleblower suits the department declines to join. Health center compliance teams can map which duties come from law and which from guidance.

U.S. Department of Justice, Office of Public Affairs

On September 18, 2026, CMS asked the court in Massachusetts v. Oz to uphold the work rule's frailty test. Enrollees with listed conditions must prove significant impairment to be exempt. If it loses, CMS wants the rule sent back without being struck down, citing the January 1, 2027 start, and the hearing is October 20.

U.S. District Court, District of Massachusetts — Massachusetts v. Oz, No. 1:26-cv-12962, Dkt. 138-1 (defendants' memorandum, via CourtListener RECAP)

Breach letters posted by Massachusetts regulators on September 18 and 25, 2026 show the Aesto data-archiving breach reached Ocracoke Health Center in North Carolina and Health Access Network in Maine. Neither appears on Aesto's own list of affected clients, last updated September 8. Any health center that used Aesto to archive an old EHR should ask the vendor directly.

Massachusetts Office of Consumer Affairs and Business Regulation (breach letters 2026-1569 and 2026-1608)

Governor Newsom approved AB 173 (Committee on Budget, health trailer bill) on September 18, 2026, and it was chaptered as Chapter 252, Statutes of 2026 the same day. Read from the Legislative Counsel's digest: DHCS may already impose a 180-day moratorium on enrolling new Medi-Cal providers to protect public funds, and the law previously exempted certain clinics and health facilities; AB 173 removes that exemption and requires notice to the Joint Legislative Budget Committee every 180 days a moratorium is in effect. It lets DHCS, with federal approval, deny or terminate a provider that discloses a risky affiliation within the prior five years, and makes a temporary suspension effective the day notice is sent rather than 15 days later. For immigrants with a specified status, it restructures eligibility so that from October 1, 2026 through June 30, 2027 those not described in certain federal provisions receive full-scope state-funded Medi-Cal; pregnant and postpartum people are exempted from the dental limitation; and maintenance dialysis becomes a covered service under restricted-scope Medi-Cal from October 1. For health centers, the moratorium change matters most to anyone planning a new site or new provider enrollment.

California Legislative Information — AB 173 history and Legislative Counsel's digest (Chapter 252, Statutes of 2026)

CMS announced on September 18, 2026 that 40 states and Puerto Rico have signed agreements to join the GENEROUS Model, its Medicaid drug-payment model that ties prices to what other wealthy countries pay, and that remaining states have until September 30, 2026 to sign. CMS estimates $64.3 billion in savings over ten years. The model launched in January 2026 and runs for five years. The release does not list which states signed and says nothing about 340B or health centers, so any effect on health center pharmacy revenue is not addressed.

CMS press release (Sept. 18, 2026)

Taylor v. Kennedy, Jr. (D. Md. No. 1:26-cv-03705) was filed September 18, 2026 and assigned to Judge George L. Russell III. The plaintiffs are five Medicaid enrollees, the American College of Physicians, the American Academy of Pediatrics, the Society for Adolescent Health and Medicine, Doctors for America, the New Hampshire Medical Society, the New Hampshire chapter of the AAP and the City of Columbus, Ohio, represented by the National Health Law Program and Democracy Forward with legal aid partners. They sue HHS, CMS, Secretary Kennedy and Administrator Oz under the Administrative Procedure Act, claiming the interim final rule's medical-frailty provisions are contrary to law and arbitrary and capricious, and ask the court to stay those provisions under 5 U.S.C. § 705, vacate them and enjoin them. Through September 22 the docket shows summonses and admissions of counsel; no stay or preliminary-injunction motion has been filed. This is a separate case from the states' challenge, Massachusetts v. Oz, which is set for a hearing on October 20. The rule itself remains in effect.

CourtListener docket, Taylor v. Kennedy, Jr., No. 1:26-cv-03705 (D. Md.); complaint filed by National Health Law Program and Democracy Forward

AB 2756 was signed and chaptered on September 18, 2026. The official California Legislative Information history records “Approved by the Governor.” and “Chaptered by Secretary of State - Chapter 309, Statutes of 2026.” on that date, after the Senate passed the bill 39-0 on August 20 and the Assembly concurred in Senate amendments 78-0 on August 24. The word “Vetoed” does not appear on the history. The act adds Section 14132.916 to the Welfare and Institutions Code, requiring the Department of Health Care Services to establish a list of Medi-Cal vision performance measures covering utilization, access and availability by January 1, 2028, to post that list with calendar-year 2026 data by January 1, 2029 and annually thereafter, and to set an initial benchmark for each measure by July 1, 2029 for use beginning in calendar year 2030, across both fee-for-service and managed care. Boundary: this supersedes the prior reading here that the measure was proposed and not yet law. Enactment still establishes no FQHC payment, no patient entitlement, no site-level performance result and no current staffing duty — the chaptered text names neither federally qualified health centers nor prospective payment, sets no rate and changes no benefit, and subdivision (a)(4) requires the department to report a measure only where it already has a data source, expressly not requiring new data collection.

California Legislative Information

Community clinics, L.A. Care and Los Angeles County agencies launched Keep LA Covered on September 17, 2026, as the San Fernando Valley Sun reported. More than a million residents face Medi-Cal changes, including work rules and six-month renewals that start January 1, 2027. Health centers can sign up staff as Coverage Champions to help patients renew on time.

San Fernando Valley Sun (September 23, 2026)

On September 17, 2026, a federal judge in Pennsylvania dismissed a suit by the National Family Planning & Reproductive Health Association over priorities in the 2027 Title X funding notice. The notice gives 35 of 100 scoring points to alignment with agency priorities, and the court said the claims are not yet ripe. The groups can refile later.

U.S. District Court, Middle District of Pennsylvania — National Family Planning & Reproductive Health Association v. Kennedy, No. 1:26-cv-01684, Dkt. 73 (memorandum, via CourtListener RECAP)

On September 17, 2026, Reps. Jack Bergman and Don Davis introduced H.Res. 1558, which says health centers should keep one patient definition for all services, including 340B drugs. The resolution cites HRSA's definition of a patient as anyone with at least one countable visit a year. It went to the Energy and Commerce Committee.

U.S. Government Publishing Office (GovInfo) — H.Res. 1558 (IH)

On September 17, 2026, the HHS Office for Civil Rights settled with Ambry Genetics over a 2020 phishing attack that exposed data on 225,370 people. Ambry paid $700,000 and accepted two years of monitoring over gaps in risk analysis, access removal and unique user logins. OCR urged every health care provider to keep its risk analysis current.

U.S. Department of Health and Human Services, Office for Civil Rights

On September 17, 2026, Make the Road New York and three other groups sued DHS in Manhattan federal court to vacate the new public charge rule. Their complaint cites a DHS estimate of about $13 billion a year in lost benefits for some 2.1 million people. The judge will hear all three related suits on October 9.

U.S. District Court, S.D.N.Y. — Make the Road New York v. DHS, No. 1:26-cv-08129 (CourtListener docket)

In State of New York v. U.S. Department of Homeland Security (S.D.N.Y. No. 1:26-cv-07978), the 21-state challenge to the new public charge rule filed September 14, Judge Ronnie Abrams signed an order on September 16 setting an initial conference for October 9, 2026 at 3:00 p.m. in New York. The entries after the complaint are summonses, admissions of counsel and service; the states have not asked the court for a temporary restraining order or preliminary injunction, so the rule that took effect September 18 stays in force while the case proceeds. For health centers, the practical question for immigrant families this fall is unchanged: the rule applies now.

CourtListener docket, State of New York v. DHS, No. 1:26-cv-07978 (S.D.N.Y.), Dkt. 17

A PPIC survey of likely voters, taken September 4 to 10, 2026, found 34% would vote yes on Proposition 44 and 61% no. The measure would penalize nonprofit community clinics that spend less than 90% of revenue on program services. Support stays near one in three across partisan groups ahead of the November 3 vote.

Public Policy Institute of California

Stanislaus County supervisors adopted a $1.95 billion budget for 2026-27 on September 15, 2026. It sets aside $20.5 million in case H.R. 1 forces the county to restart its Medically Indigent Adult program, and its Health Services Agency deletes 36 vacant positions, including two community health worker jobs.

Stanislaus County Chief Executive Office (2027 Adopted Budget, Board agenda item 7.1)

CMS said on September 15, 2026 that its ACCESS chronic-care model will add heart failure, COPD, substance use disorder and tobacco cessation tracks. The new tracks start in spring 2027, and 160 organizations now take part. Primary care teams can refer Original Medicare patients to ACCESS participants listed at Medicare.gov/ACCESS.

Centers for Medicare & Medicaid Services

Public Health Watch reported on September 15, 2026 that worry and confusion persist after California moved its immigrant dental cut to July 1, 2027. About 2.3 million immigrants now face that date, and by September DHCS had not formally told plans to call members. State data show over 220,000 immigrants dropped or lost coverage from January through June.

Public Health Watch (Salina Arredondo)

The Census Bureau reported on September 15, 2026 that 26.7 million people, or 7.9%, were uninsured for all of 2025, not statistically different from 2024. Medicaid coverage fell 0.5 percentage points, including 0.6 points for adults 19 to 64. These figures describe the year before the enhanced Marketplace credits expired.

U.S. Census Bureau (CPS ASEC)

Fresno County adopted a $5.49 billion budget on September 14, 2026, and Tulare adopted $2.26 billion the next day, as The Business Journal reported. Fresno cuts public health nearly $10 million and 16 positions, sets aside $10 million for indigent care, and will scale back mobile health. Tulare expects people who lose coverage to return to Tulare County Medical Services.

The Business Journal (Fresno), September 18, 2026

A PPIC survey released September 15, 2026 found 52% of likely voters back Proposition 40, the one-time billionaire tax that would mostly fund health care. Majorities also back Propositions 41 (51%) and 42 (54%), and either one voids Proposition 40 if it gets more votes. Californians vote November 3.

Public Policy Institute of California

San Diego County cut the ribbon on a $29 million substance use treatment and recuperative care center in National City on September 14, 2026. It adds 73 residential treatment beds and 16 recuperative care beds for Medi-Cal members and opens this fall. South Bay health centers can refer patients who need residential treatment or a safe place to heal.

County of San Diego Communications Office (County News Center)

Governor Newsom approved AB 2161 on September 14, 2026, and it was chaptered as Chapter 209. People renewing during a six-month check who meet all other rules keep Medi-Cal until at least the end of the month their 30-day response period ends. Before denying coverage, DHCS must consider every other basis for Medi-Cal eligibility.

California Legislature (leginfo)

On September 14, 2026, NACHC backed the CMS plan to keep waiving the in-person visit rule for health center mental health telehealth through December 31, 2027. NACHC says a 2.5% update does not resolve a PPS rate built on old costs, and that Medicare pays health centers about half the in-person rate for medical telehealth.

National Association of Community Health Centers (NACHC)

Healthcare Dive reported on September 14, 2026 that Johnson & Johnson began requiring 340B providers to submit claims data for each of its drugs dispensed or administered in order to keep receiving upfront 340B discounts, effective September 15, 2026. The article states the policy "applies to all 340B providers, including hospitals and community health centers, except for those in HIV/AIDS programs," that providers have up to 45 days for most drugs to submit the documentation, and that if providers fail to comply J&J "could suspend their access to all 340B discounts." It separately reports a contract-pharmacy restriction — described in the article in terms of hospitals receiving 340B pricing at only one contract pharmacy within 40 miles of the parent site — with an effective date of November 3 for grantees. Boundary: this record rests on trade reporting, not on J&J's own policy document, which was not obtained; the article's 20% to 50% savings range is stated for hospitals and is not an FQHC figure; and the article does not spell out how the 40-mile contract-pharmacy limit applies to a Section 330 grantee's sites, so treat the November 3 grantee date as the verified fact and the operative mechanics as unconfirmed.

Healthcare Dive (Sept. 14, 2026)

On September 14, 2026, 21 states, Pennsylvania's governor and the District of Columbia sued the Department of Homeland Security and U.S. Citizenship and Immigration Services in federal court in Manhattan (New York v. DHS, No. 1:26-cv-07978), challenging the public charge final rule published July 20, 2026 at 91 FR 45324. The complaint says the rule takes effect September 18, 2026, removes meaningful guidelines for what immigration officers may consider, and will lead noncitizens and their family members, including U.S. citizen children, to disenroll from programs for which they remain eligible. It alleges that the resulting loss of funding will disproportionately affect hospitals in low-income communities and community health centers, including community clinics and federally qualified health centers that already operate on very thin margins, and that some safety-net providers will need to reduce services or close. These are allegations; the court has not ruled. The case is assigned to Judge Ronnie Abrams, and through September 17 the docket showed no motion to postpone the rule.

U.S. District Court, S.D.N.Y. — New York v. DHS, No. 1:26-cv-07978 (complaint filed Sept. 14, 2026)

DHCS told counties on September 11, 2026 that it began mailing work and six-month renewal notices to New Adult Group members in late August. Counties must add the letter to application packets from October 1 through December 31, 2026. The member letter says the rules take effect in March 2027, and health center enrollment staff can expect questions.

California Department of Health Care Services (MEDIL I 26-25)

On September 10, 2026, HHS announced nearly $25 million for 132 small rural hospitals in 13 states through HRSA's Rural Hospital Provider Assistance Program. HRSA says the money helps hospitals keep physicians and nurses and reduce the risk of avoidable closures. Health centers can check the award list for hospital partners in their service area.

U.S. Department of Health and Human Services (HRSA)

In a September 10, 2026 letter, Open Door Community Health Centers CEO Tory Starr said the Humboldt and Del Norte County health center will no longer initiate hormone therapy or prescribe puberty blockers for patients under 19; patients already receiving these treatments continue their care. The letter says HHS revised its Grants Policy Statement so a grant can be terminated "for convenience" if a program no longer aligns with agency priorities, and that losing federal grant funding "would place our Federally Qualified Health Center (FQHC) status at risk." It says continuing to start these treatments could jeopardize resources that support care for more than 60,000 patients in the two counties, that care teams are arranging referrals patient by patient, and that Open Door will resume the services if the federal policy is reversed.

Open Door Community Health Centers — community update from CEO Tory Starr (Sept. 10, 2026)

CORRECTION AND RESOLUTION (2026-09-12): we previously reported that the direction of this guidance was unknown. It is known, and it RESTRICTS. We obtained the notice and its attached draft from DHCS's own server and read them. Two dates in our earlier item were also wrong: the notice's RELEASE DATE is 8/7/2026, not September 9, and the written-comment window closed August 21, 2026 — a reader relying on our earlier entry would have believed comments were still open. DHCS will still accept late comments but says they "will continue to be accepted after this date, but DHCS may be unable to assure consideration prior to finalizing the proposed guidance." 🔑 WHAT THE DRAFT DOES: the notice attaches a DRAFT FQHC/RHC OUTREACH REIMBURSEMENT POLICY that adopts the Medicare Provider Reimbursement Manual (CMS Publication 15-1) "to apply to the Medi-Cal program by reference," then gives a non-exhaustive list of SIX example reimbursable outreach activities against TWELVE non-reimbursable ones. Its stated premise, verbatim: "Section 330 of the Public Health Service Act requires RHCs and FQHCs to conduct extended outreach and education to patients and the general population which are in some cases beyond the scope of the Medi-Cal FQHC/RHC benefit. Therefore, not all outreach and education activities performed by RHCs and FQHCs are allowable for the purposes of the Medi-Cal PPS reimbursement rate." 🔑 THE SHARPEST EDGE: "Enrollment assistance or eligibility support performed by clinic or contracted staff" is listed as NON-reimbursable, while "Referral of individuals seeking care at the RHC or FQHC, who are not enrolled in health coverage, to third-party enrollment resources" is reimbursable. DHCS would recognize the cost of REFERRING an uninsured patient elsewhere but not the cost of a health center's own staff doing the eligibility work. Also non-reimbursable: broad public outreach (health fairs, public events, mass advertising, social media); group wellness activities; outreach partnerships or subcontracting with community organizations; cash or cash-equivalent incentives; free or subsidized non-health-related services; payments for referrals or member recruitment; publicized enrollment incentives and promotional commercials; public relations activities; staff leisure or retreat activities; unlicensed medical screenings; political or religious activities. 🔑 WHY THE MECHANISM MATTERS: this is a rate-base rule, not a billing rule. The draft states the PPS rate "is generally calculated based on all-patient allowable costs divided by all-patient visits," so a cost ruled non-allowable leaves the numerator — the effect is a lower per-visit rate going forward, not a denied claim. Staff who split their time must document the allocation, and any time study "must comply with the Medicare Provider Reimbursement Manual (CMS Publication 15-1, section 2313.2 (E)) and must be conducted during the fiscal year under audit." DHCS is proceeding under WIC section 14132.100(r), which lets it act "by means of a provider bulletin or similar instruction without taking regulatory action" — so there is no APA rulemaking process here. ⚠️ WHAT THIS DOES NOT ESTABLISH: the guidance is DRAFT and DHCS can revise it before October 6; both lists are described by DHCS as non-exhaustive, so neither is closed. The document states NO dollar figure and no rate impact anywhere — do not model one. THIS ITEM MAKES NO PAYMENT OR BILLING CLAIM: nothing here says an FQHC may or may not bill any code. One internal inconsistency in the source, recorded rather than resolved: the cover reads "RELEASE DATE: 8/7/2026" while the page-2 footer reads "DHCS PUBLIC NOTICE 8/3/2026"; the September 2 addendum states "On August 7, 2026" and is treated as authoritative. The non-reimbursable column also contains one bullet glyph with no text, so a careful reader may count thirteen; twelve is the number of actual examples. The remaining input channel before October 6 is the stakeholder webinar on Wednesday, September 16, 2026, 4:00–5:00 p.m.

California Department of Health Care Services, Provider Rates Division — NOTICE OF GENERAL PUBLIC INTEREST, "FQHC/RHC OUTREACH & EDUCATION PPS REIMBURSEMENT GUIDANCE," release date 8/7/2026, with the DRAFT FQHC/RHC OUTREACH REIMBURSEMENT POLICY attached at pages 3-4. dhcs.ca.gov returns a 212-byte JavaScript shell to ordinary automated fetches; the PDF was retrieved from the department's own origin by first establishing a session on the FQHC/RHC page and then requesting the file with same-origin navigation headers, and read directly.

HRSA said on September 8, 2026 it will update the 340B OPAIS registration, recertification and change-request forms on October 1. Changes include new shipping-address questions that help HRSA decide whether a location should register separately, and Tribal Agreement numbers for FQHC 638 entities.

HRSA Office of Pharmacy Affairs — 340B Program Update: Upcoming 340B OPAIS Updates

HRSA's Program Assistance Letter 2026-05, dated September 8, 2026, sets final changes for calendar-year 2026 UDS reports due in February 2027. It removes managed care member months, the Table 5 service addendum and 11 Table 6A lines, and adds type 1 diabetes and developmental disability lines. Enabling services are renamed patient support services.

HRSA Bureau of Primary Health Care (PAL 2026-05)

CMS posted a state implementation deck on medical frailty under the Medicaid community-engagement interim final rule on September 8, 2026. It restates that a person in one of the five frailty categories counts as medically frail only if the condition significantly impairs the ability to comply, and tells states to check frailty using claims adjudicated in the prior 12 months (paid, pended or denied), encounter data and other health data such as health information exchange feeds before asking the person. The deck is guidance to states, not a new rule. For health centers, it means the diagnoses coded on encounters and sent to HIEs are part of the evidence states will use to exempt patients automatically; under-coded chronic conditions can leave a patient to prove frailty on paper. This is also the provision the new Taylor v. Kennedy suit challenges.

CMS / Medicaid.gov — Implementing Medical Frailty (state deck, posted Sept. 8, 2026)