Years of relationship building, reasoned negotiations, and sound policy work positioned California Primary Care Association (CPCA) staff to engage in direct negotiations with the Department of Health Care Services (DHCS) on the most recent State Plan Amendment (SPA) related to FQHC payment provisions (18-003). The SPA notice was first issued by DHCS in December 2016 and the state’s intention at that time was to submit in March 2017. CPCA staff aggressively fought back against such a short timeline and was successful in securing an additional year for negotiation.

To ensure a robust member engagement process, CPCA staff scheduled meetings with member health centers nearly two times a month for the entirety of 2017 to share the most recent discourse with DHCS and to gather member input. CPCA worked closely with the California Association of Public Hospitals (CAPH) on the SPA as they, too, have FQHCs in their membership, in addition to two legal teams.

The proposed SPA 18-003 was submitted to CMS on March 30, 2018 with an intended effective date of January 1, 2018.


A number of changes were made in this SPA. CPCA staff were successful in securing many wins for community health centers through thoughtful and meaningful dialogue with DHCS. These changes include the following:

  • Marriage and family therapists (MFTs) as billable providers in an FQHC as of January 2018

  • Revised productivity standards (from 4200 to 3200 for clinicians, and from 2,100 to 2,600 mid-levels) with exceptions
  • Effective date for a new rate is based on 90 days from the date of written notification of federal approval 
  • Changes in scope (CIS) to require full fiscal year and to be paid at the new rate retroactive to the date the change occurred, not the year the scope change was submitted as it is today
  • Triggering events on or before December 30, 2018 use old CIS rules, triggering events on or after December 31, 2018 use new CIS rules.
  • Officially updated what had been secured through legislation in years past- intermittent sites from no more than 20 to no more than 30 hours

Thanks to CPCA and member advocacy, the state dropped damaging proposals to require a CIS to take three years for full review and audit and adjust every health center’s Prospective Payment System rate based on the most recent audited home office allocations, regardless if every health center was under audit. 

The state also responded to our concerns about the way the Four Walls section was drafted, indicating that there was not sufficient time for dialogue. CPCA will lead a subsequent conversation with DHCS on the issues of visits outside of the Four Walls, with the agreed intention to submit a new SPA in October 2018. A SPA 2.0 process has yet to commence, but will begin in late spring focusing solely on the issues of “Four Walls.” 

If you have questions regarding the SPA, please contact CPCA’s Director of Government Affairs Andie Patterson.