Inadequate Medicaid Reimbursement

We represented the Community Health Center Association of Connecticut (CHC/ACT) and other Federally Qualified Health Centers (FQHCs) in connection with pursuing Medicaid change in scope rate adjustment requests, including pursuing all administrative remedies and any settlement discussions or arbitrations relating to any rate adjustment denial. Connecticut’s Federally Qualified Health Centers (FQHCs) provide primary medical, dental, and behavioral health care to 440,000 people annually, and are required to serve all comers irrespective of income level or ability to pay. But many of these FQHCs face dire financial straits because the Connecticut Department of Social Services (DSS), contrary to its avowed mission, has persistently breached its legal duty to pay FQHCs statutorily compliant reimbursement rates for medical, dental, and behavioral healthcare services rendered to Medicaid beneficiaries. With underserved patients’ access to critical services imperiled, the Community Health Center Association of Connecticut (CHC/ACT), has begun the process of taking legal action to address DSS’s longstanding noncompliance. CHC/ACT’s petition seeks a declaratory ruling that federal and state law require DSS regularly to review and adjust FQHCs’ Medicaid rates to account for any changes in these FQHCs’ scope of services – all without the irrelevant analyses, pretextual denials, and undue delay that have characterized this rate-setting process until now. While specifically focused on Connecticut, the petition implicates legal principles of nationwide consequence. A link to CHC/ACT’s Press Release. In May, 2025, an agreement was reached as to the following: A three-year phase in of new rates, reflective of 2023 costs for each health center, beginning on October 1, 2025; a new “change in scope” process;  change the appeals process for Federally Qualified Health Centers to align with other Medicaid providers beginning January 1, 2027; and withdrawal of the declaratory ruling request.