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SPEC·05 · FQHC & Community Health

PPS, sliding-fee, UDS, 340B. The whole community-health stack.

Federally qualified health centers run on a different financial model than fee-for-service medicine. Wraparound payments, PPS rates, sliding-fee scales, UDS deadlines, and 340B obligations all interact. and miss any one of them and your federal compliance posture cracks.

Compliance posture
HRSA, UDS,
340B, 501(r)
Built into the workflow.
Compliance isn’t a quarterly attestation. It’s the design of every encounter, every claim, every report.
What we run

Six functions tuned for the FQHC payment model.

Generic RCM teams treat FQHCs like physician groups. They aren’t. PPS rate billing, wraparound capture, and sliding-fee administration are the difference between sustained operations and grant dependence.

01

PPS rate billing

Per-visit prospective payment, billed correctly to Medicare and Medicaid. Encounter qualification rules respected. Same-day-multi-encounter rules applied per state Medicaid manual.

Medicare PPSMedicaid APM/PPSSame-day rules
  • Encounter qualification: face-to-face requirement, qualifying provider, scope-of-project alignment.
  • Same-day rules: medical + dental + behavioral same-day handled per state Medicaid policy.
  • Rate updates: PPS rate changes loaded the day they take effect, not the next quarter.
02

Wraparound & reconciliation

MCO encounter data submitted on time. Wraparound (supplemental) payments reconciled quarterly to the PPS rate. Variance pursued, not absorbed.

MCO encountersWraparound captureQuarterly reconciliation
  • Encounter submission: per-state MCO encounter data on the state’s schedule, not ours.
  • Reconciliation: MCO paid + state wraparound vs. PPS rate, by encounter, quarterly.
  • Recovery: gaps appealed; if MCO under-encountered, state notified.
03

Sliding-fee scale administration

HRSA-compliant sliding-fee design and administration. Family income verified, document trails maintained. Patient-pay portion sized to the schedule and explained in the patient’s language.

HRSA-compliantIncome verificationBilingual
  • Verification: documentation collected at registration, not chased post-visit.
  • Patient communication: bilingual scripts; the patient knows what they pay before they pay it.
  • Audit posture: schedule and methodology documented for HRSA OSV.
04

UDS reporting alignment

UDS data quality is the year’s most stressful three weeks. We align registration, coding, and patient demographics throughout the year so January isn’t a fire drill.

UDS table alignmentYear-round QASubmission support
  • Year-round QA: data-quality checks against UDS tables monthly, not in January.
  • Service-line alignment: medical, dental, behavioral, vision, enabling services tagged correctly.
  • Submission support: dedicated lead works with your UDS officer through the BPHC submission window.
05

340B contract pharmacy & eligibility

Eligibility determination, contract-pharmacy reconciliation, and OPAIS posture. We work with your 340B program manager to keep the audit trail clean and the savings calculations defensible.

OPAIS alignedContract-pharmacy reconAudit trail
  • Eligibility: patient eligibility per HRSA definition, documented at the encounter.
  • Reconciliation: contract-pharmacy reports vs. eligible-encounter data. ineligibles excluded.
  • Audit posture: ready for HRSA 340B audit, not assembled in a panic.
06

Grant & cost-report support

Section 330, MUA/MUP designations, and Medicare cost report (CMS-222) prep. Revenue, cost, and statistical data assembled cleanly so your finance team isn’t reverse-engineering a year of work in two weeks.

Section 330CMS-222Cost / stat alignment
  • Cost-report data: revenue, cost, and statistical data tied out year-round.
  • Grant alignment: Section 330 reporting reconciled to financials, not reconstructed.
  • Designation support: MUA/MUP and HPSA paperwork supported when designation is up for renewal.
Where FQHC revenue typically leaks

Six structural leak points.

LEAK 01
Wraparound never claimed

MCO under-encounters, state wraparound never paid because it was never asked for.

LEAK 02
Same-day rule mishandled

Medical + dental + behavioral same-day billed wrong for the state. One denial creates a pattern.

LEAK 03
Sliding-fee documentation gap

Family income not verified at the encounter. Patient pay never collected, federal compliance at risk.

LEAK 04
UDS January fire drill

Year of data quality issues surfaced in three weeks. Clinical, registration, and finance fight under deadline.

LEAK 05
340B eligibility creep

Ineligibles included in 340B claims. Audit risk silent until HRSA arrives.

LEAK 06
Cost-report scramble

Stat data and revenue data not tied year-round. CMS-222 reverse-engineered under deadline pressure.

Engagement format

Five phases. Same partner.

DAY 1-15
PPS & wraparound read

90 days of encounters reviewed for PPS qualification, wraparound capture, same-day discipline.

DAY 16-30
Sliding-fee & UDS

Sliding-fee documentation audit. UDS data-quality baseline established by service line.

DAY 31-60
Cutover

FQHC bench assigned. State Medicaid matrix loaded. Wraparound reconciliation cycle started.

DAY 61-90
First reconciliation

First quarterly wraparound reconciliation. Sliding-fee compliance check. UDS QA on track.

QUARTERLY
QBR + UDS prep

Senior partner walks scorecard. UDS readiness reviewed. 340B audit posture confirmed.

What we put in writing

Six SLAs. FQHC-specific.

METRICTARGETWHY IT MATTERS
PPS encounter qualification99%+% of submitted encounters that meet HRSA face-to-face / scope criteria. Audit-defensible.
Wraparound recoveryQuarterlyMCO + state wraparound vs. PPS, reconciled per encounter. Variance pursued, not absorbed.
Sliding-fee documentation98%+% of self-pay encounters with HRSA-compliant income verification on file.
UDS data qualityYear-roundMonthly UDS-table QA across registration, coding, demographics. No January fire drills.
Days in AR (dollar-weighted)35-45FQHC-typical range. State-Medicaid mix-adjusted.
340B audit readinessContinuousOPAIS-aligned eligibility data, contract-pharmacy reconciliation. Audit-ready, not panic-assembled.
THE STRUCTURAL CHOICE

FQHC is a different financial model. Generic RCM doesn’t fit.

PPS, wraparound, sliding-fee, 340B, UDS, cost reports, Section 330. these aren’t edge cases, they’re the operating model. Our FQHC bench is dedicated, has 10+ years per senior, and reads HRSA PIN updates the day they post. Your federal compliance posture is the asset; we keep it intact.

WHAT THAT MEANS IN PRACTICE

Federal-compliance fluency, not generic billing.

  • HRSA-fluent senior. reads PIN/PAL updates the day they post.
  • Year-round UDS QA. no January scramble, no surprises in BPHC submission.
  • Wraparound discipline. MCO + state reconciled quarterly, by encounter.
  • Sliding-fee audit-ready. documentation collected at the encounter, not retroactively.
  • 340B compliance. OPAIS-aligned, contract-pharmacy reconciled, ready for audit.
FQHC scorecard

Four monthly outcomes.

PPS qualification
% encounters meeting HRSA criteria
Audit-defensible
Wraparound capture
Reconciled quarterly
Per-encounter variance
UDS readiness
Year-round QA
No January scramble
340B posture
OPAIS-aligned
Audit-ready continuously

Get a free wraparound + UDS read.

Send us last quarter’s wraparound reconciliation and your most recent UDS submission. We’ll send back a 4-page diagnostic on capture, qualification, and data-quality risk. No obligation.

Book a 30-min audit

Pick a slot. No SDR triage.

Talk to a senior ASP-RCM partner about your FQHC. 30 minutes. Bring your last UDS submission, your PPS wraparound reconciliation, or your sliding-fee mix questions. Built for 330-grant operators.

FOR FQHC CFOS + BILLING DIRECTORS

30 minutes with a senior partner.

Free. Same calendar a senior partner and directors live in. The next available slots are below.