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Policy Update 12/16/21

By Cassidy Heit posted 01-11-2022 11:13

  

Vaccine Mandate Still On Hold in 14 States 


On Wednesday, December 15, the Fifth Circuit Court of Appeals partially upheld and partially reversed an injunction issued on November 30 by the Western District Court of Louisiana. The November decision issued a nationwide preliminary injunction against the CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule (IRF) in 40 states and was separate from a Missouri decision that affects 10 states.

The opinion by the Fifth Circuit Court of Appeals stayed the injunction in the 14 states that brought the lawsuit in the Louisiana, which includes Oklahoma. Though the vaccine mandate is no longer on hold in 26 states, it is unclear when enforcement of the mandate will begin, especially since the Phase 1 deadline for policies and procedures was December 6. Health centers "should continue to be ready to put in place the policies and procedures necessary to comply with the CMS vaccination mandate." Health centers can also move forward with their policies and procedures to implement COVID-19 vaccine mandates.
 

Policy & Advocacy

SoonerCare Expansion Members & PCMH Selection


The Oklahoma Health Care Authority (OHCA) has announced that starting January 1, 2022, SoonerCare Choice Expansion Adult members will ​be required to get a referral from their patient-centered medical home (PCMH) / primary care provider (PCP) in order to see a contracted specialist. No referral has been required to see a specialist for these members so far, but on January 1st, 2022, this flexibility will be removed and referrals will be required for SoonerCare Choice Expansion Adults seeking specialty care. Health centers seeking guidance on strategies to encourage PCP selection can contact cheit@okcpa.org.
 

Surprise Billing Rule Webinars &Toolkit


Free Webinars: The National Association of Community Health Centers is hosting a webinar for health centers on surprise billing requirements which take effect in January 2022. Join the facilitated discussion on the No Surprise Billing Act on Friday, December 17 at 1:00 PM CT. Register here.

Feldesman Tucker Leifer Fidell (FTLF) is also hosting a webinar entitled, "The No Surprise Act: Getting Your Health Center Ready for Implementation," and OKPCA has purchased access to the webinar on behalf of all members. Click here to register for the webinar and use code OKPCA_SURPRISE to view it for free through the end of 2021. View the slides here in the OKPCA member portal. Notes are also available in the portal. If you do not have access to the portal but would like to, contact cheit@okpca.org or complete this form.

Toolkit: Starting January 1, 2022, community health centers will be required to provide uninsured patients with a Good Faith Estimate (GFE) of their expected out-of-pocket costs for services, if the individual schedules the service at least three business days in advance, or otherwise requests information about charges.

The U.S. Department of Health and Human Services (HHS) and several other federal agencies recently published the Part II interim final rule (IFR) implementing portions of the No Surprises Act. The rule specifically outlines the “good faith estimate” requirements for uninsured or self-pay individuals as well as the dispute resolution processes dispute resolution processes for surprise medical bills. Health centers will be required to comply with these “good faith estimate” requirements.

A “toolkit” addressing new requirement for CHCs to provide uninsured patients with Good Faith Estimates (GFE) of their out-of-pocket charges, effective January 1. The GFE toolkit contains:
  • A summary of the requirements and timelines;
  • FAQs organized by topic;
  • A draft template a GFE form that health centers can adapt for their use; and
  • A flowchart outlining operational steps, such as if and when a GFE must be provided.
Click here to view the toolkit. Contact grassroots@okpca.org with questions.
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