Many federally qualified health centers (FQHCs) in California lack specialty care services for their patients. But FQHCs that want to add specialty services face significant legal and regulatory barriers. An FQHC seeking to include specialty care must make certain that those services will fit within federal regulations, that the health center will be fully reimbursed for them, and that its individual providers will have liability protection regarding those services. This paper is intended for FQHCs and FQHC Look-Alikes that are expanding services to include specialty care. It outlines the federal laws and regulations that govern the provision of and reimbursement for specialty services by FQHCs. It also addresses the more limited role of California state law and agencies, most significantly involving Medi-Cal reimbursement but also facility, equipment, and professional licensing and permitting. The paper suggests how an FQHC can best comply with these complex federal and state rules, and includes practical checklists targeted to each set of important issues for a clinic adding specialty services.
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