The rate resets October 1. Who owns the 90-day reprocessing window?

The plan owes the money. You have to own the tracking.

The question that arrives in every October finance meeting is some version of: once the new rate loads, who goes back and fixes the encounters already paid at the old rate, or do we assume the plans handle it?

In Pennsylvania the answer is written down, and it is the plan. DHS notifies the Medicaid MCOs of completed retroactive PPS rate changes each quarter, the plans then have 90 days to reprocess every paid encounter back to the effective date, and the handbook puts the money itself on the plan in both directions. The HealthChoices agreement turns that into a contract duty with a $30,000 sanction attached.

None of that tells you it happened. The clock starts on a notification date you never see, it runs against a population of encounters only your system can enumerate, and the state's remedy is a sanction on the plan, not a report to you. So the obligation sits with the plan and the tracking has to sit with the center. If you are outside Pennsylvania, the odds are that no reprocessing rule exists in your state at all, which means the tracking is not just prudent, it is the only control there is.

The Pennsylvania mechanics, in the state's own words

The reset itself. The annual update lives in the State Plan, not in the provider handbook. Attachment 4.19-B, item 8 says:

"Beginning October 1, 2001, and for each fiscal year thereafter, the Department will pay FQHCs/RHCs, on a per visit basis, the amount paid for the preceding fiscal year, increased by the percentage increase in the Medicare Economic Index (MEI) applicable to primary care services for the current fiscal year, adjusted to take into account any increase or decrease in the scope of such services furnished by the FQHC/RHC during that fiscal year." Pennsylvania Medicaid State Plan, Attachment 4.19-B, FQHC Services page 2c (approved and effective April 1, 2025)

That sentence is the whole basis for the October 1 anchor. The FQHC/RHC handbook never states it, so a finance team working from the handbook alone is working from memory. Note also what is not published: as of September 18, 2026 we could not locate any PA DHS notice, bulletin or Pennsylvania Bulletin item announcing the October 1, 2026 MEI percentage. Pennsylvania rates are provider-specific and DHS notifies each center by letter, so there is no statewide rate table to check. Do not plan against a percentage you have not received in writing.

The notification and the 90 days. Appendix E of the PROMISe Provider Handbook carries the operative paragraph, word for word identical in the November 1, 2024 edition posted on the provider handbooks page and the January 1, 2026 edition issued as Attachment 4 to Bulletin 99-26-01:

"The Department notifies the MA MCOs of retroactive PPS rate changes that have been completed each quarter. The MA MCOs have ninety (90) days from the date of the Department's notification to complete claims reprocessing for any paid encounter with a date of service back to and including the effective date of the PPS retroactive rate change. The obligation for payment to the FQHC/RHC, or to collect overpayments from the FQHC/RHC, is maintained by the MA MCO." Appendix E, FQHC/RHC Handbook, post-audit final reconciliation. Same language introduced by Medical Assistance Bulletin 08-24-04, March 1, 2024.

Three operational facts fall out of that paragraph. The notification is quarterly and batched, so your rate change and the plan's trigger are separate events on separate dates. The reprocessing reaches back to the effective date with no floor, so the exposure is the full period, not a rolling window. And the money runs both ways, which means a downward adjustment is a recoupment the plan is entitled to take.

The enforcement. The teeth are in the MCO contract, not the handbook. The HealthChoices Physical Health Agreement effective January 1, 2026, Section VII.E.5, repeats the 90-day clock and adds:

"The PH-MCO must send notification to the Department that it reprocessed the Claims as required within 10 Business Days of the completion of the required Claims reprocessing." ... "Failure to complete the required Claims reprocessing for each FQHC and RHC and to submit notification of the completion of the Claims reprocessing to the Department will result in the full assessment of the 90 Day Claims processing sanctions in Section VII.D.2 totaling $30,000. In addition to the sanction amount, the Department will complete a settlement in place of the PH-MCO's Claims reprocessing for the FQHC or RHC." HealthChoices Physical Health Agreement, Section VII.E.5.f. The 2026 document is footed "Pending Final Approval"; the identical 90-day clause appears in the posted final January 1, 2025 agreement.

There is a backstop, and it is DHS settling in the plan's place and recovering from the plan. But the backstop only fires if the failure is visible, and nothing in either document obliges the plan to tell you.

The second clock nobody watches

Reprocessing is the fast clock. The wraparound settlement is the slow one, and it is the one that quietly expires. Appendix E sets the filing cadence and a hard outer limit:

"FQHCs and RHCs are required to submit the quarterly MCO settlement report seven (7) months after the end of each calendar year quarter." ... "The Department will not accept a Wraparound Report or revision to a prior period Wraparound Report for quarters that are more than two years beyond the required submission date. The Department limits to the two-year timely filing per 45 CFR 95.7." Appendix E, FQHC/RHC Handbook, quarterly MCO settlement report

The seven-month lag is the trap. A retroactive rate change can affect encounters whose wraparound quarter was reported long before the new rate existed. The fix is the revision, and the revision expires two years from the original due date, not from the date you learned the rate changed.

Most states publish nothing. Here is who publishes what.

We reviewed the published FQHC and RHC rate methodology, retroactive adjustment and wraparound rules for all 50 states on September 18, 2026. In 30 of them, no rule on who reprocesses already-paid encounters after a retroactive rate change, or within what timeframe, could be located in the regulations, provider manual or state plan. That is not a claim that the money never moves. It is a claim that if it fails to move, there is no published standard to point at. Among the states that do publish something, several publish a refusal rather than a duty.

Each state row is quoted from the document linked on the state name. Pennsylvania's sources are linked in full in the Sources block below.

Your reset date is probably not October 1

"The rate resets October 1" is true in eight states and wrong in the rest. From the published methodologies:

• October 1 Arizona, Connecticut, Florida, Nebraska, New York, Ohio, Pennsylvania, Virginia.
• January 1 Hawaii, Illinois, Iowa, Mississippi, Montana, New Jersey, Washington.
• July 1 Arkansas, Kentucky, Louisiana, Missouri, New Hampshire, Rhode Island, South Dakota (APM election opens July 1, 2026; annual increases begin July 1, 2027), Tennessee.
• Your own fiscal year Colorado sets new encounter rates 120 days after each center's fiscal year end. Texas calculates the effective rate at the start of each FQHC's own fiscal year. Wisconsin adjusts the PPS rate by the MEI in effect at the end of each center's fiscal year.

Minnesota, North Dakota and South Carolina are deliberately absent. Each has a widely repeated reset date that we could not confirm against a readable primary document on September 18, 2026, so we are not printing it.

What to run, and when

At the effective date: take the snapshot. On the day your new rate takes effect, freeze a claim-level extract of every Medicaid managed care encounter already paid with a date of service on or after that effective date: claim number, plan, date of service, paid amount, rate applied. This is the only baseline that exists. You cannot reconstruct it later once the plans start adjusting.

Day zero: log the notification date per plan. Ask each plan in writing for the date it received the state's retroactive rate notification, and record it per plan. In Pennsylvania this is the date the 90 days runs from, and it is the one fact you cannot derive from your own data. Different plans may carry different dates from the same quarterly batch.

Day 60: run the delta report. Re-pull the same population and compare paid amount against the encounter count multiplied by the new rate. Sixty days in gives you a full month to escalate before the window closes. A plan that has reprocessed nothing by day 60 is not going to finish by day 90 without a conversation.

Day 90: escalate with claim-level evidence. Not a summary, not a total. A list: claim number, date of service, paid amount, expected amount, variance. In Pennsylvania, add one question: ask the plan for the completion notification it owes DHS within 10 business days. That question is answerable and it is uncomfortable.

Keep the ledger. Roll every reset into a standing reconciliation ledger by rate period: effective date, notification date, reprocessing due date, encounters in scope, dollars expected, dollars recovered, dollars written off and why. That ledger is what feeds the annual reconciliation and, in Pennsylvania, the wraparound revisions that expire two years after their original due date.

If you are not in Pennsylvania

Work the question in three steps rather than assuming your state looks like the one in the article.

One. Find out whether a reprocessing rule exists. Check the state plan attachment 4.19-B, the FQHC and RHC provider manual or administrative rule, and the Medicaid managed care contract. In 30 of 50 states we found nothing on this point in any of the three. A blank is an answer: it means there is no deadline to enforce and the reconciliation is the only path.

Two. Find the clock that does exist. Every state has one, and it is often not the one you expect. In Ohio the wrap claim expires on its own schedule. In Washington the June 10 roster cutoff ends the argument for the prior year. In Florida a scope increase cannot reach back more than 75 days before the request. In Hawaii, filing scope notice later than 60 days moves the effective date to the notification date. Wyoming settles nothing retroactively at all. Whichever one governs you, put it on the compliance calendar as a hard date and work backwards from it.

Three. Run the snapshot and the ledger anyway. Where a duty is published, the ledger is how you enforce it. Where nothing is published, it is the only evidence that will start the conversation, and in states that settle at the rate level rather than the claim level it is also how you check the state's math.