FQHCs Regulatory Compliance
Federally Qualified Health Centers and look-alike organizations.
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Total Enforcement Actions
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Actions This Year
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Total Penalties Tracked
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Critical / High Severity
Regulatory Overview
Federally Qualified Health Centers receive Section 330 grant funding from HRSA contingent on meeting access, quality, and governance requirements. FQHCs must maintain sliding fee scales, demonstrate service to underserved populations, and comply with Uniform Guidance (2 CFR 200) for federal expenditures. CMS also certifies FQHCs for Medicaid PPS reimbursement, adding a second enforcement layer.
Primary Enforcement Focus
HRSA program reviews, OIG billing audits, and HHS OCR civil rights complaints dominate enforcement. Loss of 330 grant jeopardizes FQHC status and look-alike eligibility.
Common Violation Patterns
Sliding Fee Schedule Non-Compliance
Charging patients who qualify for discounts the full fee, or failing to apply sliding fee to the uninsured.
Grant Misuse / Cost Allocation
Using 330 grant funds for non-allowable costs, improper indirect cost rates, inadequate time-and-effort documentation.
Credentialing / Scope of Practice
Providers rendering services outside their licensed scope; inadequate privileging documentation for visiting specialists.
Medicaid Billing Errors
Billing encounters that do not meet visit documentation standards, or billing for services not within FQHC scope of project.
Enforcement Actions — FQHCs
Violations Signal Board
Latest FQHCs NewsAll
National Health Expenditure Projections, 2025–34: Strong Utilization Growth Initially, Legislative Impacts Later
Health Affairs, Ahead of Print.
Medicaid Asset Limits And Enrollment Among Older Adults And People With Disabilities
Health Affairs, Volume 45, Issue 6, Page 708-715, June 2026.
Not enough time
Health Affairs, Volume 45, Issue 6, Page 716-716, June 2026.
Price Transparency, Medicare, Medicaid, And More
Health Affairs, Volume 45, Issue 6, Page 613-613, June 2026.
The Opacity Of Price Transparency
Health Affairs, Volume 45, Issue 6, Page 614-621, June 2026.
Key Regulations
Section 330 of the Public Health Service Act
Foundational grant authority. Requirements include underserved area designation, sliding fee schedule, and consumer-majority board governance.
2 CFR Part 200 — Uniform Guidance
Federal grant cost principles, audit requirements (Single Audit >$750K), and internal controls for all federal expenditures.
Medicaid FQHC PPS (42 USC 1396a)
Prospective payment system rate-setting. FQHC must document that services align with scope of project to bill PPS rate.
HIPAA 45 CFR Parts 160 & 164
Full HIPAA applicability. FQHCs handle high volumes of sensitive SUD, behavioral health, and reproductive health records.
Sliding Fee Discount Schedule
Must be available to all patients; income-based tiers required. HRSA reviewers routinely audit sliding fee schedule compliance.