NCMS Morning Rounds 12-20-21

Happy Monday! Enjoy your NCMS Morning Rounds!

December 20, 2021

Message from NCMS EVP & CEO Chip Baggett

No Surprises Act Template Now Available

A sample policy and procedure for Good Faith Estimates is now available. This document has been prepared by Colleen Meiman for Federally Qualified Health Centers (FQHCs) but must be tailored to your organization’s approach to compliance with the No Surprises Act. As a reminder, the requirement for Good Faith Estimates goes into effect on January 1, 2022.  This template is also available starting on page 32 of the GFE Toolkit.  The toolkit is continuously updated so please bookmark the link for future reference.

As you are aware, the Community Health Centers (CHC) community is currently waiting for CMS to respond to public comments on the Interim Final Rule, and potentially revise how those rules apply to CHCs.  During this interim period, CHCs are taking a variety of approaches to issues such as when to issue GFEs and the type of charge data to include.  This template can be tailored to reflect various approaches to these and other issues.  Regarding when to issue a GFE, the template offers language for three (or four) potential approaches, as follows:

  • Option One:  Full compliance with the wording of the current IFR.  CHCs who take this approach will provide a GFE every time an uninsured or self-pay patient schedules an appointment at least three days in advance — regardless of whether the patient requests one.
  • Option Two*:  These CHCs will provide GFEs only when uninsured or self-pay patients request them.  Some will require their staff to ask each uninsured/self-pay patient if they want a GFE when they schedule an appointment 3 or more business days in advance; others will not have their staff offer a GFE proactively but will provide one if the patient asks for it.
  • Option Three*:  These CHCs will automatically provide a GFE every time they expect that the uninsured or self-pay patient’s out-of-pocket costs will be at least $400.  This approach ensures that patients have the documentation necessary to pursue the Independent Dispute Resolution process established under the No Surprises Act any time they might be eligible.
  • *Options Two and Three:  Many CHCs are combining these options, planning to provide GFEs every time a patient requests one and/or the patient’s costs will be at least $400.

Rural Communities Opioid Response Program-Behavioral Health Care Technical Assistance (RCORP-BHCTA)

The Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy (FORHP) will award up to $10 million per year for one technical assistance provider to support Rural Communities Opioid Response Program (RCORP) grant recipients’ efforts to develop, implement, and sustain behavioral health, including substance use disorder, interventions in rural communities. In collaboration with HRSA, the recipient will provide customized technical assistance to grant recipients in a variety of formats and be responsive to the health care needs and priorities of rural communities.  A technical assistance webinar for applicants will be held on January 11, 2022 from 2-3 p.m., ET.

Quarterly 340B Program Registration

Quarterly 340B Program site registration is open from January 1 to 15, 2022. Health centers will be able to register a site that has been verified as implemented and with a site status reflected as “active” in EHBs Form 5B through Friday, February 25, 2022. After that date, the system will close to prepare for the April 1, 2022, start.

Email the 340B Prime Vendor Program or call 888-340-2787 (Monday-Friday, 9:00 a.m.-6:00 p.m. ET) to register a new site or ask questions. You will need to provide the following information when calling:

  • Health center name.
  • Site/clinic name.
  • Site IDs for all sites.
  • HRSA/BPHC grant number.
  • Contact name and email address.
  • Authorizing official name and email address.

The authorizing official will receive an email message that the account is unlocked and a registration may be submitted.

In the News

CDC recommends Pfizer, Moderna COVID-19 shots over J&J’s, AP, 12-17-21

Learning Opportunity

Join us at the Grandover in Greensboro as we gather for the 2022 North Carolina Dermatology Annual Meeting!

The Annual Meeting program features outstanding faculty who will address current topics of interest to the practicing dermatologist and dermatopathologist. This year’s program focuses skin of color and includes presentations on hidradenitis suppurativa, updates in laser and light treatments, management of vitiligo and dyschromia, in addition to clinical presentations and an important legislative update. The schedule includes daily breaks and a Friday evening reception in a networking hub presenting products and services to help the dermatology practice. These events will provide an opportunity to renew friendships and meet new colleagues.

Learn more and register here.


If you have policies you’d like your NCMS Board of Directors to consider, please complete the Board input form here. Thanks for reading!


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